The Minor Servicing Exemption - WMC
The Minor ServicingExemptionLOTO’s Misunderstood RequirementCarlos GallegosAssistant Area Director - Response TeamAurora Area Officegallegos.carlos@dol.govGoals Review LOTO application– Define employee roles– Review Acceptable Isolation Devices– Compare Machine Guarding to LOTO– Special Equipment/Circumstances Discuss the “Minor Servicing Exception”1
Goals Review Machine Guarding– When is Machine Guarding sufficient Related Standards E-Stops Performance and Control Reliability– Safeguards– Circuit Integration (relays contactors) Examples of machine guarding in Minor ServicingRegion V Top 10 Most Frequently Cited 9285841005005National Top 10 Most Frequently Cited (Manufacturing FY-16)116967956349949744631631230128262
Presentation References 29 CFR 1910.147 The Controlof Hazardous Energy(Lockout/Tagout) CPL 02-00-147 The Control ofHazardous Energy –Enforcement Policy andInspection Procedures ANSI B11.19-2010 AmericanNational Standard forMachines – PerformanceCriteria for SafeguardingDefinitions "Affected employee." An employee whose jobrequires him/her to operate or use a machine orequipment on which servicing or maintenance isbeing performed under lockout or tagout, orwhose job requires him/her to work in an area inwhich such servicing or maintenance is beingperformed.1910.147(b)8Definitions "Authorized employee." A person who locks out ortags out machines or equipment in order to performservicing or maintenance on that machine or equipment. An affected employee becomes an authorizedemployee when that employee's duties includeperforming servicing or maintenance covered underthis section.1910.147(b)3
Authorized Employee(CPL:Pg 1-4) Any employee who implements a lockout and/ortagout system procedural element on machinesor equipment (for servicing and/or maintenancepurposes) is considered an authorizedemployee:– perform energy source isolation;– implement lockout and/or tagout on machines orequipment;– dissipate potential (stored) energy;– verify energy isolation;– implement actions to release LOTO; or– test or position machines or equipment.Required Training Authorized employees– Recognition of hazardous energy sources– Type and magnitude of energy in the workplace– Methods for energy isolation / control Affected employees– Purpose and use of energy control procedures Other employees in work area– Procedures related to restarting machines11Servicing and/or Maintenance(CPL:Pg 1-10) Workplace activities such as constructing,installing, setting up, adjusting, inspecting,modifying, and maintaining and/or servicingmachines or equipment. These activities include lubrication, cleaning orun-jamming of machines or equipment andmaking adjustments or tool changes, where theemployee may be exposed to the unexpectedenergization or start-up of the equipment orrelease of hazardous energy.4
Energy Isolating Device(CPL:Pg 1-5) A mechanical device that physicallyprevents the transmission or release ofenergy. Push-buttons, selector switches,safety interlocks and othercontrol circuit type devices areNOT energy isolating devices.Alternative Effective Protection? Employee reaches into the die in ahydraulic press to clean die surface, whichis done about once an hour. The press has a light curtain for protection.Assume this is minor servicing work. Is the employee considered authorized oraffected?14Adequate device forenergy isolation?5
CPL 02-00-147; Pgs. 3-25 Thru 3-32MINOR SERVICINGEXCEPTION TO THELOCKOUT/TAGOUTSTANDARDLockout/Tagout & Employee Protection(CPL:Pg. 2-16) Employee Protection for Service & Maintenance Activityis achieved by:– Apply Full LOTO I/A/W 29 CFR §1910.147;– Complying with the minor servicing exception to the LOTOstandard (1910.147(a)(2)(ii)) Machine Guarding – Must provide effective employeeprotection.– Utilizing the cord and plug connected equipment or hot tapexemptions – i.e., 1910.147(a)(2)(iii)(A) and (a)(2)(iii)(B);– Complying with the machine or equipment testing orpositioning requirements of 1910.147(f)(1); Machine Guarding – Must provide effective employeeprotection.LOTO Scope 1910.147(a)(2)(ii)– Normal production operations are not covered by thisstandard (See Subpart O of this Part). Servicing and/ormaintenance which takes place during normal productionoperations is covered by this standard only if: An employee is required to remove or bypass a guard or othersafety device; or An employee is required to place any part of his or her body intoan area on a machine or piece of equipment where work isactually performed upon the material being processed (point ofoperation) or where an associated danger zone exists during amachine operating cycle.6
Minor Servicing Exception Exception to paragraph (a)(2)(ii)– Minor tool changes and adjustments, andother minor servicing activities, which takeplace during normal production operations,are not covered by this standard if they areroutine, repetitive, and integral to the use ofthe equipment for production, provided thatthe work is performed using alternativemeasures which provide effective protection(See Subpart O of this Part).Lockout/Tagout & Machine GuardingEmployee ExposureServicing & MaintenanceActivityNormal ProductionOperationsSubpart O29 CFR 1910.14729 CFR 1910.212 - 219Employee ExposureLockout/Tagout & Machine GuardingEmployee ExposureServicing & MaintenanceActivity29 CFR 1910.147MSENormal ProductionOperationsSubpart O29 CFR 1910.212 - 219Employee Exposure7
Minor Servicing Exception In order to take advantage of the limitedexception, an employer must provideeffective alternative protection in lieu ofLOTO.Lockout/Tagout & Machine GuardingGuardedGuardedGuards & Safeguarding Devices to ELIMINATE employee exposureduring the servicing and maintenance activity.Minor Servicing Exception Minor “servicing and/or maintenance”activities:– Do not require extensive disassembly of themachinery/equipment.– Can be accomplished safely with effectiveproduction-mode safeguards, (Subpart O).8
Minor Servicing Exception(CPL:Pg. 3-26) Activities requiring machine or equipment shutoff anddisassembly, such as changing a machine tool or cuttingblade, usually take place outside of the normalproduction process and require energy isolating deviceLOTO in accordance with §1910.147.– Changing Table Saw blade.– Changing Grinding Wheel, etc. Replacement of machine or equipment componentsnormally is not considered a routine maintenancefunction that can be safely accomplished when amachine or piece of equipment is operating.– belts, valves, gauges, linkages, support structure, etc. --Service/Maintenance Activity/EE Exposure to HazardNormalProductionOperation?Region V Minor Servicing (1910.147(a)(2)(ii))Decision Flow ChartNOLockoutApplies to AllService/MaintRoutine: The activity must beperformed as part of a regular andprescribed course of procedureand be performed in accordancewith established practices.YESService/MaintenanceInherent &Minor?*NOLockoutAppliesRepetitive: The activity must berepeated regularly as part of theproduction process or cycle.Integral: The activity must beinherent to the productionprocess.YESEffectiveProtection InUse? *** Inherent & Minor - Activities must benecessary to allow production toproceed and be:NOLockoutAppliesYESException Applies toService/Maintenance** Employermust demonstrate thatthe alternative measures provideeffective protection from thehazardous energy.(Subpart O; ANSI B11.19-2003; etc.)MSE Operator Initiated Safety Is it acceptable to have the employeefollow a procedure to place the machine ina safe mode, manual mode or pause theoperation as a part of the MSE effectiveprotection? NO! – With the exception of certain low riskequipment and tasks.9
Westvaco Corporation Decision(CPL:Pg. 3-26) OSHA issued a citation alleging a seriousviolation of §1910.147 because an employer didnot lockout or tagout the slotter section of aprinter/slotter machine. Adjustments to both theprinter section and the slotter section had to bemade for each order. The average number oforders run per day was three or four and eachorder change required set-up adjustments takingbetween 15 and 45 minutes to complete.Westvaco Corporation Decision What did the OSHRC decide and why?– Rejected the employer's assertion that set-upactivities associated with this equipmentconstituted minor servicing within the scope ofthe exception.– Commission Concluded setting up does not occur during normal productionoperations work performed before the normal productionoperation is not covered by the exceptionWestvaco Corporation Decision While not reaching the questions ofwhether the activities were minor [as areincluded in this exception] or whether thealternative protection was effective, theCommission concluded that adjustmentsmade while the machine was being set-upwere not adjustments made during normalproduction operations.10
MSE Operator Initiated Safety Must have a guard or safety device,properly selected and applied based ongenerally accepted good engineeringpractices. (ANSI B11.19) A procedure that involves and requires theemployee to initiate the safe condition isan Administrative Control.Hierarchy of ControlPROTECTIVE MEASUREMost EffectiveElimination orSubstitutionEngineering Controls(Safeguarding/Safeguards)Awareness MeansTraining and Procedures(Administrative Controls)Personal ProtectiveEquipment(PPE)Least EffectiveEXAMPLES Eliminate human interaction in the process. Eliminate pinch points (increase clearance) Automated material handling. Etc. Guards – Fixed, Interlocked, Adjustable, Etc.Interlocks Presence Sensing Devices - light curtains,safety mats, area scanners, etc. Two Hand Controls and Trip Devices Lights, beacons, and strobes Computer Warnings Signs and Labels Beepers, Horns, and Sirens Safe Work Procedures Safety Equipment Inspections Training Lockout/Tagout/Tryout Safety glasses/Face Shields Ear Plugs Gloves Protective Footwear RespiratorsMSE Operator Initiated SafetyIntrp Letter August 24, 2005 In low risk minor servicing applications,such as changing a tool bit on a millingmachine or a drill bit on a drill press,where the activity meets all of the criteriacontained in the minor servicing exception,servicing activities may be performedusing local disconnects or control switchesthat:11
Examples Of Effective Alternative Protection(Minor Servicing Exception)(CPL: Pgs. 3-29 thru 3-32) Changing a mixing blade on a verticalmixer or a drill bit on a single-spindledrill press.– machine's electrical disconnects or control(e.g., on/off buttons or emergency stops)switches:1. Are properly designed and applied inaccordance with recognized and goodengineering practice; and2. Control all the hazardous energy and areplaced in an off position; and3. Are under the exclusive control of theemployee performing the task.Examples Of Effective Alternative Protection(Minor Servicing Exception)(CPL: Pgs. 3-29 thru 3-32) Removal of a part that isstuck (jammed) in a plasticinjection molding machine.– Completed a cycle and is shutoff (using the stop push button).– Opening interlocked slidingoperator gate guard preventsthe machine from cycling.Examples Of Effective Alternative Protection(Minor Servicing Exception)(CPL: Pgs. 3-29 thru 3-32) The employee is positioned such thatthe interlock operator-gate providesthe employee with sufficient protection– an interlock gate guard is not adequateprotection if the employee's entire body isinside the guard area Injection molding machine safetysystems are designed, inspected,tested, maintained, and operated inaccordance with recognized andgenerally accepted good engineeringpractices; and Means of control of the machineremain in the exclusive control of theperson afforded the protection.12
Minor Servicing Exception(CPL:Pg. 3-29) An employer who is claiming that amachine servicing activity is exempted bythe minor servicing exception mustdemonstrate that they meet each andevery element of this exception.– See Falcon Steel Co., 16 BNA OSHC 1179(No. 89-2883, 1990)Examples Of Effective Alternative Protection(Minor Servicing Exception) Task Creep– Mold opened too soon or astuck plastic part melted orbecame stuck such thatLOTO is required because“other-than minor” cleaningmust be performed. e.g., prying, pulling, scrapping,and/or chipping) or evenmachine component (e.g., die)disassembly This now requires LOTOLockout/Tagout & Employee Protection(CPL:Pg. 2-16) Employee Protection for Service & Maintenance Activityis achieved by:– Using effective machine guarding, in compliance withSubpart O, that eliminates or prevents employeeexposure from the hazardous energy associated with themachines or equipment;13
Lockout/Tagout & Machine Guarding(CPL:Pg. 2-18) Point of operation requirements for machines,§1910.212(a)(3)(ii) requires point of operationdanger zone guarding in conformity with anyappropriate or applicable standard that has beenadopted as or incorporated by reference into anOSHA standard.– In the absence of such standards, the guardingdevice must prevent (and not just warn or signalemployees of the impending hazard) the operatorfrom having any part of his or her body in the dangerzone during the operating cycle.Machine Guarding/ANSI B11.19 – 2003(CPL:Pg. 2-26) OSHA will consider adherence with:– 1) guards;– 2) safeguarding devices; As primary safeguardingmethods compliant with Subpart O.Effective Employee Protection What is Effective Employee Protection orEffective Machine Guarding? American National Standard for MachineTools – Performance Criteria forSafeguarding -- ANSI B11.19-200314
Safeguarding(CPL:Pg. 1-9) Safeguarding Protective Device in the 2003ANSI standard.– Safeguarding (protective) device: A device thatdetects or prevents inadvertent access to a hazard.Devices that detect, but do not preventemployee exposure to machine hazards (e.g.,through one of the four methods in (a) through (d)above), do not comply with the machine guardingprovisions contained in Subpart O, when guards orsafeguarding devices are feasible.OSH Review Commission “Section 1910.212(a)(1) is a general machineguarding standard that applies to all machinerynot otherwise covered by Subpart O. Theguarding required mustmust bebeprovidedprovidedbybya a“device” cerelianceuponupontheskill skilltheor attentivenessor attentivenessof employees.of employees.It isIt is“intended to eliminate danger from unsafeoperating procedures, poor training or employeeinadvertence.”Cincinnati Incorporated, OSHRC Docket No. 00-0955, Final Order Date 10/02/00Machine Guarding/ANSI B11.19 – 2003(CPL:Pg. 2-26) These methods, by design, do not preventemployees from placing or having any part of theirbodies in the hazardous machine areas:– Awareness devices;– Safeguarding (work) methods;– Safe work procedures. These methods provide a lesser degree of employeeprotection and are considered to be secondarycontrol measures during normal productionoperations.15
Hierarchy of ControlPROTECTIVE MEASUREMost EffectiveElimination orSubstitutionEngineering Controls(Safeguarding/Safeguards)Awareness MeansTraining and Procedures(Administrative Controls)Personal ProtectiveEquipment(PPE)Least EffectiveEXAMPLES Eliminate human interaction in the process. Eliminate pinch points (increase clearance) Automated material handling. Etc. Guards – Fixed, Interlocked, Adjustable, Etc.Interlocks Presence Sensing Devices - light curtains,safety mats, area scanners, etc. Two Hand Controls and Trip Devices Lights, beacons, and strobes Computer Warnings Signs and Labels Beepers, Horns, and Sirens Safe Work Procedures Safety Equipment Inspections Training Lockout/Tagout/Tryout Safety glasses/Face Shields Ear Plugs Gloves Protective Footwear RespiratorsComplimentary SafeguardingEquipmentEquipment That Augments Safeguarding Devices: Safety Blocks, Slide Locks,Chain Locks, and Locking Pins Workholding Equipment Enabling Devices Stopping PerformanceMonitors Safety Interface Modules– Monitoring Safety Relays– Safety PLCs– Safety BUS Systems Emergency Stop (E-Stop)Devices– Pushbuttons– Pull Cords (Cable Pulls, TripWires)– Body Bars– Trip Rods– Footswitches (without amechanical guard) Hand ToolsTypes of Safeguarding Mechanical solutions that physicallyprevent or restrict access:– Fixed Guards– Safe Openings in Fixed Guards– Adjustable Guards– Moveable/Self Adjusting Guards– Pullbacks– Mechanical Restraints16
Types of Safeguarding Mechanical solutions that prevent accessand cycle initiation (Interconnected orInterlocked):– Interlocked Guards (With or W/O Guard Locking)– Type A&B Moveable Barriers (i.e. Gates)– Moveable/Automatic Screens– Automated Doors– Probe DetectionInterlocks and Guarding Devices What do these devices have in common?– They are all connected to the machinecontrols and generate/send a command tostop or prevent hazardous motion.– This Protective (Safety) Stop command issent through the protective stop circuit. (ANSIB11.19 - 2010: Clause 6.2.1)Design of the SRP/CS One strategy used to meet theserequirements is to design the system with;– Redundancy, and– Monitoring to ensure that redundancy ismaintained. This design strategy is called “ControlReliability” and it is used to describe theintegrity of the safety rated control system.17
Safety Related Parts of ControlSystem (SRP/CS) Are the machine’s SRP/CS “ControlReliable”?– What is the other question we should beasking? What is the Performance Level (PL) orSafety Integrity Level (SIL) of themachine’s SRP/CS?– This will tell us how well the Safety-RelatedFunction performs.ISO 13849-1 Requirement HighlightsISO 13849-1 provides safety requirementsand guidance on the principles for thedesign and integration of safety-related partsof control systems (SRP/CS), including thedesign of software. Topics include: Performance Levels–––– CategoriesDiagnostic CoverageCommon Cause FailuresMTTFdSafety FunctionsSoftware based parameterizationFault considerations and Fault exclusions53Categories – The commonmisunderstandingSafety Categories ONLY describe what happens if something goeswrong. They are NOT a measure of reliability, quality, or safety.Instead, they help answer the question “So .If this thing fails, will themachine still shut down?”The higher the category, the more measures are in place to ensure thesafeguarding device does what it is supposed to do.A higher category does NOT a mean a machine is “Safer”5418
Performance of the Safety-RelatedFunction (ANSI B11.19 - 2010: Clause 6.1) When a single failure occurs, and it oranother subsequent failure would lead tothe inability of the safety-relatedfunction(s) to respond to a normal stopcommand or an immediate stop command,the safety-related function shall:Performance of the Safety-RelatedFunction (ANSI B11.19 - 2010: Clause 6.1) Until the failure is corrected or until thecontrol system is manually reset;– Prevent initiation of hazardous machinemotion; or– Initiate an immediate stop command andprevent re-initiation of hazardous machinemotion; or– Prevent re-initiation of hazardous machinemotion at the next normal stop command.Understanding Safety CategoriesCategories range between B through 4. Oversimplified,they build off each other to ensure faults don’t lead to unsafe states: Category B: The use of “basic safety principles” – The use of standard componentswith no fault detection or fail-safe measuresCategory 1: Category B plus the use of “well-tried components” or safety-rateddevices instead of standard components.Category 2: Category B plus periodic monitoring – no action required (e.g. checkengine light on car).Category 3: Category B plus no single fault can lead to an unsafe state, single faultsmust be identified (e.g. redundancy)Category 4: Category B plus no accumulation of faults can lead to an unsafe state orall faults must be individually identified (e.g. every safety device has its own safetymonitoring relay)5719
Understanding Safety CategoriesExample SafetyFunction“DirectDrive” iagnosticCoverageFeedbackFeedback58Control Reliability – PerformanceLevel – Safety Integrity Level(Table 4 ANSI B11.0 – 2010: Clause 7.2.9.1)Acceptable Levels(Table 4 ANSI B11.0 – 2010: Clause 7.2.9.1)20
Machine Safety Statistics: Control System FailuresHSE: Out of Control 978 0 7176 2192 761Today’s Machine SafetyLandscapeMost manufacturers today are in one of these categories:Avoidance:Machines are not fullysafeguarded or there hasbeen a minimal attempt tosafeguard. “We haven’t hadan accident, haven’t had acitation – we are good to go”Illusion of Safety:There has been a valiant effortto use technology and newguarding methods to provideincreased safety, but ultimatelyis resulting in an illusion ofsafetyFort Knox:Limited understanding intechnology, standards, andregulations causes an overlyguarded, overly restrictive,high cost, and productivitylimiting safety solution62Programmable logic controllers (PLCs)?(CPL:Pg. 1-6) PLC devices are NOT considered energyisolating devices for purposes of the LOTOstandard. Safety functions, such as stopping orpreventing hazardous energy (motion),can fail due to component failure, programerrors, magnetic field interference,electrical surges, improper use ormaintenance, etc.21
What To Look For22
Review Machine Guarding –When is Machine Guarding sufficient Related Standards E-Stops Performance and Control Reliability –Safeguards –Circuit Integration (relays contactors) Examples of machine guarding in Minor Servicing Region V Top 10 Most Frequently Cited (Manufa
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