Issue link: http://palletcentral.uberflip.com/i/536121
26 PalletCentral • July-August 2015 palletcentral.com document such training. In addition, if manufacturers have warning decals (preferably bilingual to better inform diverse workforces), employers should utilize those prominently on equipment to reinforce safety training and work rules. There are two types of machinery hazards: "point-of- operation" and "mechanical motion." The types of safety controls typically utilized to mitigate such hazards include: guards, devices, location and distance, feeding and ejection methods, and miscellaneous aids. The problem is that there is no "one size fits all" solution because not only must each piece of equipment be evaluated for potential hazards, but the configuration of equipment within a plant can also be a factor as to what is compliant and what can trigger a citation. For dismantling equipment, the point-of-operation situation is the most dangerous because this is where work is performed on the material being cut. These machines have moving components that can injure a worker in the area of motion and there are various types of motions to be analyzed: reciprocating motion, transverse motion, rotating motion, and nip points. Even if workers are keeping body parts such as fingers and hands clear from the cutting edge, workers can also be injured if their clothing, hair or jewelry gets caught in a moving part. In addition, inspectors will consider other hazards associated with the operation of dismantling machines and band saws, including the hazard of being struck by flying material, and excessive noise resulting from machine operation. These hazards can be mitigated by strict enforcement of the use of safety goggles (with protective side panels) by those operating the machines, and use of appropriately-related hearing protection by not only the equipment operator but also by other workers who are in proximity to equipment that emits noise over 90 dBA over an eight-hour period. OSHA's preference is always going to be to install guards on the equipment to prevent contact with mechanical motion hazards, but inspectors can be convinced not to issue citations if they are satisfied with work procedures that can satisfactorily protect workers. For band saws and dismantling equipment in the pallet industry, OSHA has been willing to accept the following work practices in lieu of guarding, for compliance purposes: 1. Train workers not to place hands or other body parts within 12 inches of the saw blade of the machine; 2. Etch or mark a line on the saw table at the 12-inch mark to give a visual indicator of the danger zone to workers; 3. Require workers to use a "push stick" if pallets become jammed, so that hands are not used within 12 inches of the blade; 4. If the equipment is operated by two employees, one should push the pallet from one end and the other should pull the piece from the other end after it is sawed or disassembled, and both workers must keep their appendages at least a foot away from the blade; 5. If possible, lengthen tables to provide a greater safety zone, but also consider ergonomic factors that could result from such redesign, including back strains, and try to develop a solution to prevent substituting one type of injury for another (hint: a safety consultant may know of solutions that can reduce such exposures); 6. If possible, install a cover above the blade at a height that allows pallets to pass beneath it, but ensure that the manufacturer does not object to the modification of the equipment for safety reasons; and, 7. Warning decals with these work practices should be posted SAFETY Whatever practices are ultimately adopted by the employer, employee training is critical and must be well-documented.