From: peter phillips (firstname.lastname@example.org)
Date: Fri Apr 28 2000 - 19:39:01 CDT
I would very much appreciate a copy of your discussion paper as I share your
views on this subject. Jay Phillips
> The entire issue of LO/TO and press cleaning has never really been
> clarified by OSHA. The printing industry has been able to obtain some
> clarification relative to most procedures from OSHA and it is contained in a
> letter from 1992.
> Essentially the letter allows presses to not be locked out during most minor
> operations which include cleaning operations, plate changes, webbing,
> clearing of certain types as long as the equipment does not have to be
> disassembled, blanket changing (on litho presses) of paper jams by using the
> inch-safe-service method in conjunction with appropriate press control
> (e.g., warning and signaling, stop button, etc.) as specified in ANSI B65.1.
> The above approach works well when cleaning or servicing the press does not
> occur when it is moving. There have been problems with when equipment needs
> to be cleaned when it is moving, especially blankets on litho presses. There
> have been citations and challenges and to make a long story short, there
> appears to be three options for hand cleaning blankets. They are as follows:
> 1. Clean the blankets using the inch-safe-service method. The presses will
> have to be configured to meet ANSI B65.1.
> 2. Clean moving blankets by using a specially designed tool and used
> according to a procedure and special conditions.
> 3. Clean moving blankets by using a shop towel carefully folded and only on
> presses equipped with fixed and rigid nip guards that meet or exceed the
> requirements in Table O-10 of 29 CFR 1910.212. The guards are designed to
> prevent fingers/hand from being drawn into any in-going nip points or from
> otherwise being injured. This approach will require you to seek a
> site-specific letter of interpretation that will have to be issued by your
> local OSHA office.
> I have prepared a much more detailed discussion of this topic in a
> "discussion paper" along with appropriate OSHA interpretations. Let me have
> your address and I will send it along.
> Gary Jones
> Graphic Arts Technical Foundation
> 200 Deer Run Road
> Sewickley, PA 15143
> 412/741-6860 x608 - Phone
> 412/741-2311 - Fax
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