From: Jeff Adrian (email@example.com)
Date: Fri Apr 28 2000 - 08:10:58 CDT
Re: Lock-out/tag-out enforcement of press 4/28/00
Mike and Others:
OSHA permits an alternative to Lo/To for the purposes of "minor servicing"
and "set up" of printing equipment (and they define what minor servicing
and set up means with examples).
The alternative means can only be applied to those tasks that are routine
(occuring on a regular basis), repetitive (and thus are well practiced),
and itegral to normal operations (not some unusual task).
The alternative means must protect against sudden and unexpected startup,
and each employee performing servicing on a piece of equipment (when
multiple employees are performing work) must have access to and control of
their own STOP/SAFE button. That button must stop all motion either before
the motion begins (during the programmed time delay period) or after the
motion has started. In order to protect against unexpected motion there
needs to be both a signal prior to motion commencing and a programmed time
delay period after the signal and before motion begins.
These last requirements are not necessary when the piece of equipment is
operated by and under the sole control of a single operator.
I hope this lends some clarity to what can be a confusing issue.
Director, Environment & Safety The John Roberts Company
Robert Gifford wrote:
>>From: Mike Rogovein <firstname.lastname@example.org>
>>At the recent NEHS conference in Cincinnati, there was discussion
>>concerning OSHA's revisiting their policy on how they inforce LO/TO regs in
>>regard to press cleaning. I don't remember who made the comments, but
>>hopefully someone in sight of the message can help.
>>1> where do we now stand in regard to LO/TO during cleaning a press?
>>2> is "cleaning a press" limited to removing ink, or can it be construed
>>to include cleaning a paper ball-up out of the machine?
>>Thanks, Mike Rogovein
>Printers' National Environmental Assistance Center, and
>Univ. of Wisconsin - Extension
>Solid and Hazardous Waste Education Center
>610 Langdon St., rm 531
>Madison WI, 53703
>Voice: 608-262-1083 Fax: 608-262-6250
>PNEAC: www.pneac.org, 1-888-USPNEAC (faxback)
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> Subject: Lock-out/tag-out enforcement of press cleaning
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