(The following is taken from the employers reference manual of the "Press Brake Safety Compliance Kit," produced by the Sheet Metal and Air Conditioning Contractors' National Association.)
Companies involved in metal fabrication assemble a wide variety of products - metal ductwork, architectural structures, roofing components, kitchen equipment, industrial-ventilation systems (and) metal frames. Many of the components involved in the production of these systems are fabricated using the press brake. The press brake operator, on a normal day, may be faced with hundreds of pieces of varying shapes, sizes and types of metal, which may undergo one of a series of bends on the press brake.
Due to the fabrication process of such a wide variety of piece parts, standard guarding by physical barriers or devices is not feasible to protect workers from the point of operation on the press brake. In Section One, we stated that in such instances, OSHA (the Occupational Safety and Health Administration) will allow safeguarding to be accomplished by maintaining a safe distance of 4 inches from the point of operation when the use of physical barriers or physical devices is not feasible to protect an employee operating a power press brake.
What are the employer's responsibilities?In order to use safeguarding by "maintaining a safe distance" procedures, OSHA states that each employer must do the following:
· Demonstrate that physical barriers and devices are not feasible.
· Limit the use of these procedures to the fabrication of custom pieces (small-quantity runs).
· Have a workplace history of employees operating power press brakes safely.
· Maintain a safety program which includes safe work practices, training, supervision and periodic inspections.
Why standard guards are not feasibleSection One of this manual outlined several types of guards and guarding devices that can be used to protect press brake operators from the point of operation. While these will work effectively for high-volume production runs of the same piece, when the job being performed is custom in nature, these types of guards would have to be changed or adjusted for each piece of material. This would pose an undue constraint on productivity and, therefore, OSHA has recognized that in such instances, the use of these guards or devices is infeasible.
OSHA does, however, require employers to state why the guards and devices available are not practical for their particular operation. Here is a list of limitations imposed by each type of guard or device on the custom fabrication of metal products.
Fixed barrier: The fixed barrier would have to be changed for each piece part depending on the material and the type of bend being performed.
Adjustable barrier: As with (the) fixed barrier, this guarding device adequately protects workers during production cycles; however, the use of a gate or removable barrier during custom operations may still leave the point of operation unprotected during parts of the cycle.
Two-hand controls: This is not a practical method of guarding because the metal that is being fabricated usually has to be held by the operator.
Pullbacks: There are numerous problems with the use of these devices. They may create other hazards by obstructing the work space around the operator and they only work if the operator is in one position. During custom operations, there is a high mobility of the operator.
Process-sensing devices (light curtains): This equipment is expensive and will leave a machine unprotected when there is a mechanical failure of the device. In addition, the fabrication of some materials will necessitate a gap large enough for the operator's fingers or hand to enter the point of operation undetected, and they are difficult to use when making multiple bends on metal such as those in custom operations.
Restraints: The use of restraint devices generally pose the same problems as pullbacks.
Small-quantity runsAs previously stated, the safe-distance method of safeguarding is only to be used for small-quantity runs of made-to-order or custom-made piece parts. A small-quantity run means that fabrication of the same piece part is not being fabricated for a continuous time frame of more than four hours.
Typically, in the type of custom or job-shop establishment common to the sheet metal industry, each table of metal to be fabricated on the press brake will contain a wide variety of piece parts of differing sizes, shapes and gauges of metal. Additionally, some of the metals may be TDC - Transverse Duct Connection - or have sound-lining material attached.
If there will be the high-volume continuous fabrication of the same piece-part, a production run, the safe-distance procedures do not apply.
Workplace history· The employer using the safe-distance method of safeguarding on the power press brake must also demonstrate a workplace history of safe operation. This history can be established by showing an absence of serious injuries related to failure to maintain a safe distance from the point of operation. The following company records can be used to meet this requirement:
· OSHA 200 log
· Company injury/illness reports
During an OSHA inspection, the workplace history will be evaluated by a compliance officer reviewing such employer records and interviewing or observing employees.
Safety programAnother condition for safeguarding by maintaining a safe distance states that the employer must have a safety program that includes the safe work practices and procedures to be used by employees and an effective employee-training program. The safety program must also include provisions for the supervision of employees to ensure that work is being performed using the safe-distance alternative measures.
SMACNA reminds readers that the criteria for ensuring that this program is applicable and accepted by OSHA are very strict and must be closely followed and fully documented. There is no guarantee that a company will avoid OSHA citations while implementing these procedures.
(For information on ordering a copy of SMACNA's "Press Brake Safety Compliance Kit," which includes a training video and other materials, write to 4201 Lafayette Center Drive, Chantilly, VA 20151; call (703) 803-2989; fax (703) 803-3732; see www.smacna.org on the Internet.)