Chapter 25
Machine Safeguarding—Shop and Lab Machine Safety
Contents
Approved by Michael Wisherop
Revised June 2008
25.1
Policy
25.2 Scope
25.3 Definitions and Support
Organizations
25.4 Overview
25.5 Acquisition and Installation of Machine
Tools, Machine Equipment, and Guarding
25.6 Qualifications
25.6.1
Qualifying Research Personnel to Perform Work in User Shops
25.7 Machine Tool and Machine
Equipment Guarding Requirements
25.7.1 Approach
for Guarding Unique and Specialized Laboratory Machine Equipment
25.8 Inspection and Maintenance
25.9 General Safety Rules for Power Tool Use
25.10
General Safety Rules for Use/Maintenance of Machine Tools, Machine Equipment,
and Power Tools
25.10.1 Safety Rules
for the Use and Maintenance of Laboratory-Specific Machine Equipment
25.10.2
Safety Rules for Use and Maintenance of Office Machine Equipment
25.11 Responsible Parties
25.11.1
Division Directors
25.11.2 Supervisors,
Work Leaders, and Shop Managers
25.11.3 Employees and Other Machine Tool,
Machine Equipment, and Power Tool Users
25.12 Standards
25.13 Related PUB-3000 Chapters
25.14 Appendices
Appendix
A. Application
to Use Shop Equipment
Appendix B. LBNL
Nonlaboratory Machine Guarding Requirements
Appendix C. LBNL Laboratory Machine Equipment Guarding
Requirements
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25.1 Policy
It is the policy of Lawrence Berkeley National Laboratory (LBNL) to safely operate
and maintain machine tools, power tools, and machine equipment in shops,
laboratories, equipment rooms, on construction sites, and in other locations. It
is the responsibility of division line management to provide machine guarding
and to ensure that it is being used to protect operators, researchers, and
other employees from hazards. Machine tools, machine equipment, and power
tools may only be operated and/or maintained by authorized personnel working in
accordance with the requirements of this chapter.
25.2 Scope
These safety requirements apply to all LBNL employees, subcontractors,
vendors, and guests who work with or perform maintenance on machine tools,
machine equipment, or power tools.
25.3 Definitions and Support
Organizations
For the purposes of this chapter, the following definitions apply:
- “Authorized person” means a person approved or assigned by line
management to perform a specific duty or duties, or to be at a specific
location or locations at the workplace.
- “Machine equipment” means any piece of machinery not described
above as a tool. Machine equipment includes building systems equipment, such as
building HVAC systems, air compressors, and mechanical pumps, as well as
scientific equipment such as centrifuges, tensile test machines, sample polishers,
etc.
- “Machine tool” means any fixed (nonportable) or tabletop machines
used to cut, shape, or otherwise alter materials. Machine tools are not
limited to shops and may be found in other areas, such as laboratories and
construction sites. Machine tools include, but are not limited to, machine
shop tools (saws, lathes, grinders, milling machines, drill presses, etc.),
woodworking tools (table saws, jointers, planers, etc.), and specialized shop
tools (pipe cutters/threaders, power shears, power brakes, rolling mills, swaging
equipment, etc.). The term “shop tool” is loosely synonymous with “machine
tool.”
- “Power tools” mean portable machine tools (hand drills, hand
grinders, circular saws, routers, etc.).
- “Qualified person” means a person who, through experience,
sufficient knowledge, or training, can operate specific machine tools, power
tools, and/or machine equipment safely, as well as identify and mitigate
hazards associated with the use of such equipment.
- “Shop” means any area designated as such by line management, in
which one or more machine tools and or power tools are used.
- The Occupational Safety Group is a part of the Environment,
Health, and Safety (EH&S) Division and provides expertise including machine
guarding requirements, and machine tool, power tool, machine equipment, and shop
safety.
- The Electric Shop is a Facilities Division group responsible for
electrical utilities.
- Machine Tool Services is an Engineering Division group whose
qualified personnel repair and maintain mechanical tools and equipment.
25.4 Overview
Machine tools, power tools, and machine equipment are capable of causing
serious injuries, amputations, and even death. Traditionally, the use of such
equipment is restricted to technical and/or crafts personnel who have been
trained in the proper application, operation, or maintenance of such equipment.
At LBNL, other personnel may operate machine and power tools to help
construct or modify experimental equipment or components. When required by the
level of hazard, this work is authorized by division line management with a Job
Hazards Analysis (JHA), Activity Hazard Document (AHD), or equivalent. Work is
planned and carried out by personnel who have been assessed by line management for
their skill, knowledge, and abilities to perform the specific tasks with these
tools.
If a worker’s skills, knowledge, abilities, or resources are insufficient to
operate or maintain machine and power tools within the constraints of this
chapter, please contact the Engineering or Facilities Division shop managers so
that the work can be performed by skilled technical or crafts personnel.
When the level of hazard requires it, the operation and maintenance of
machine equipment other than machine tools requires division line management
authorization. Authorization verifies that line management has ensured that workers
have the necessary skills, knowledge, and abilities to operate and/or maintain
the machine equipment.
Authorization exists for the repair, maintenance, and operation of building
system machine equipment by appropriate Facilities Division HVAC and Electrical
Shop personnel.
25.5 Acquisition and
Installation of Machine Tools, Machine Equipment, and Guarding
All new machine tools and equipment must be procured with all guarding
required by Occupational Safety and Health Administration (OSHA) 29 CFR 1910 and,
when applicable, by national consensus standards applying to the specific
equipment. Specify these guarding requirements in the requisition to the
vendor so that they can be furnished with the equipment.
If purchasing used equipment, acquire and retrofit all required guarding
before the equipment is placed in service. Consider the cost and difficulty of
retrofitting to determine whether surplus equipment is a prudent acquisition.
Contact the EH&S Division Occupational Safety Group or the Engineering
Division Machine Tool Repair and Maintenance Group for assistance in
determining which guards are required, where to purchase them, and how to
install them.
Secure all newly acquired equipment to OSHA machine safety and LBNL seismic
safety standards, and ensure that it is wired as described in Section 25.10(d),
by qualified electricians within current electrical code requirements. Contact
the Machine Tool Repair and Maintenance Group in the Engineering Division for
assistance with securing equipment, and the Facilities Division Electric Shop
for electrical installations.
25.6 Qualifications
There are no formal LBNL training courses covering the technical use of
machine tools, machine equipment, or power tools. Employees and managers are
qualified through trade experience, equipment manufacturers’ courses, documented
on-the-job training (OJT), and/or demonstrated skill and abilities on the use
of equipment within designated areas (shop, lab, facility, fieldwork location,
etc.) in which they work.
While certain Facilities Division Heating, Ventilation, and Air Conditioning
(HVAC), Plant Maintenance Technicians (PMTs), and Electrical Shop employees are
qualified through trade experience, OJT, and/or demonstrated skill to maintain
and operate most building system machine equipment, new or unique machine
equipment may require specific training from the manufacturer.
Line management is expected to evaluate employee skill levels prior to
assigning work. If an employee is hired to perform a skilled trade in which he
or she is qualified, or has extensive experience operating a particular piece
of equipment, a JHA provides sufficient training documentation. Except as
noted, the JHA process ensures that the employee authorized to use a machine
tool, power tool, or piece of machine equipment is qualified to do so.
At the discretion of division management, additional safety training for
shop/lab managers may include understanding their scope of responsibility,
EH&S requirements, oversight and observation, as well as coaching and
mentoring techniques.
25.6.1 Qualifying Research Personnel to
Perform Work in User Shops
Research personnel who wish to become qualified to perform limited shop work
need documented OJT specific to the machine tool in question. This may be
achieved by using the optional Application to Use Shop Equipment (Appendix A),
or an approved equivalent qualification process. The Occupational Safety Group
may approve qualifications processes found to be equivalent to the application
process.
If choosing to use the application process, potential users must first
submit an Application to Use Shop Equipment for each piece of equipment they
want to use to their division shop manager or the Engineering Division
Researcher Shop in Building 77. The shop manager or Engineering Division
representative reviews the application and administers a safe operation skills
check for each machine. The shop manager or Engineering Division
Representative may deny qualifying individuals who do not exhibit the ability
to safely operate the piece of equipment, or in cases where the equipment
requires a higher level of training to acquire the necessary qualifications. Based
on the hazards of the machine, the shop manager and/or work authorization may
require documented OJT in addition to the safe operations skills check.
Personnel not qualified to operate machine or power tools may choose to
contact their local division shop manager or the Engineering Division to have
the fabrication/modification work done for them.
25.7 Machine Tool and Machine Equipment
Guarding Requirements
It is line management’s responsibility to ensure that machine tool and
machine equipment guarding is adequate. Never remove factory-installed guards
unless they are designed to be removed for a particular operation, and
equivalent means of protection are used (e.g., table saw guards are removed for
fence cuts; when appropriate, push sticks are used).
Guard all reasonably accessible points of operation, pinch and nip points,
rotating parts, and flying chip or spark hazards that may expose an employee to
injury. In general, guarding prevents inadvertent contact with these hazards.
Guarding may be achieved by one or more methods, such as isolation, barriers,
shields, devices, or distance.
LBNL follows federal OSHA standards for machine guarding, which address
specific requirements for many types of machine tools, machine equipment, and
power tools. While these standards are accessible to anyone, the EH&S
Division Occupational Safety Group is available to provide guidance and
interpretation of machine guarding requirements. While most operators and
managers can identify obvious machine dangers, they may not know how to identify
or handle subtle machine hazards. Contact the EH&S Division Occupational
Safety Group if you are not certain whether a machine tool, machine equipment,
or power tool needs guarding.
Appendix B provides a more detailed description of LBNL machine guarding
requirements, examples of machine hazards and guards, as well as a Machine
Tool, Machine Equipment, and Power Tool Safety Checklist. The checklist may be
used for self-assessments, walkarounds, or inspections of areas where such
equipment is located.
25.7.1
Approach for Guarding Unique and Specialized Laboratory Machine Equipment
While certain highly specialized and unique laboratory machine equipment is
still required by OSHA to guard against machine hazards that expose an employee
to injury, guarding may not be included by the manufacturer. This may also
apply to legacy Laboratory-designed and built (homemade) equipment. In these
cases, alternative guarding/and or controls may be designed. Contact the
Occupational Safety Group to help assess guarding requirements and options.
Appendix C provides a more detailed description of LBNL laboratory machine
equipment guarding requirements, examples of laboratory machine equipment
guards, as well as a Laboratory Machine Equipment Safety Checklist. The
checklist may be used for self-assessments, walkarounds, or inspections of
areas where such equipment is located.
25.8 Inspection and Maintenance
Machine tools, machine equipment, and power tools should be routinely
inspected to verify that they are not damaged, that the controls function as
designed, and that all guarding and shields are securely installed and
adjustable. Servicing, including cleaning, lubrication, preventive maintenance,
and adjustment of machine equipment and machine tools can help prevent
performance and safety problems. Only qualified technicians authorized by line
management or qualified vendors are permitted to service equipment. Service
equipment only when all electrical, hydraulic, compressed air, and stored
energy sources are secured in accordance with the requirements of PUB-3000, Chapter 18 (Lockout/Tagout).
The Facilities Division HVAC, Plant Maintenance Technicians (PMTs), and
Electrical Shops are the only LBNL personnel authorized to maintain and repair building
system machine equipment. Subcontractors may be authorized to work on building
system machine equipment through the submittal review and approval process.
Other machine equipment may only be maintained by qualified technicians authorized
by division line management, or qualified vendors.
25.9 General Safety Rules for Power Tool Use
The following rules apply to the use of power tools, regardless of their
location.
- Permit only qualified personnel who have necessary skills through
experience and/or training, and who have been appropriately authorized (JHA,
AHD, etc.) as determined by division line management, to operate power tools.
- Formal authorization, such as a JHA, is required for power tools that
expose personnel to injury, even if they are commonly used by the public.
Examples include circular saws, nail guns, and RotoHammers.
- Power tools that pose minimal hazards and are commonly used by the
public may be used without authorization. Examples include 3/8-inch chuck-size
drills, impact wrenches, electric screwdrivers, and electric bolt drivers.
- Use
all required guards and Personal Protective Equipment (PPE).
- Ensure
that all personnel wear required PPE when entering areas where power tools are
operated and/or other hazards exist.
- Prohibit
persons under the age of 18 from operating any dangerous power tool unless the
work is part of an approved apprenticeship program. Dangerous tools include
but are not limited to circular saws, chain saws, high-torque drills, and
abrasive wheels greater than two inches in diameter.
- Permit
only qualified (trained and certified) and authorized personnel to operate
powder-actuated tools (i.e., cartridge-actuated). Acquire a penetration permit
from the Facilities Division for penetrations as required by Facilities
Division Administrative Procedure 053: Permit to penetrate ground or excavate
surfaces of LBNL property.
- Use Ground Fault Circuit Interrupters (GFCI) on all cord and plug
electric power tools used for construction, outdoor, or damp location work.
- Do
not use fuel-powered tools in indoor locations unless their use has been
approved by the EH&S Division, Industrial Hygiene Group. Shut down
fuel-powered tools before refueling, servicing, or maintenance. Handle and
store fuel in accordance with OSHA 29 CFR 1926, Subpart F.
- Permit
only qualified and authorized personnel or vendors to repair or otherwise
service power tools.
25.10 General Safety Rules for
Use/Maintenance of Machine Tools and Machine Equipment
The following general rules apply to the use and/or
maintenance of machine tools and machine equipment, regardless of their
location.
- Permit only qualified
personnel who have necessary skills through experience and/or training,
and who have been appropriately authorized (through JHA, AHD, etc.) as
determined by division line management, to operate or maintain machine
tools or machine equipment.
- Equip all machine tools,
power tools, and machine equipment with all required guarding, and
prohibit (lock and tag) their operation unless such guarding is in place
and fully functional.
- Operate/maintain machine
tools, and machine equipment in accordance with the manufacturer’s
requirements, and the requirements of this chapter.
- Anchor and electrically wire
all machinery and machine equipment designed by the manufacturer to be stationary.
Only qualified electricians are permitted to install and remove wiring for
hardwired shop machinery and machine equipment. Machine tools and machine
equipment designed to be electrically connected by cord and plug are not
subject to this requirement.
- Permit only qualified and
authorized personnel or vendors to repair or otherwise service machine
tools or equipment.
- Only operate machine tools
when a second person is within sight or earshot of the tool user. This is
an essential requirement in the case of personnel who get caught in
machinery or suffer traumatic injuries. The second person need not be
qualified to operate the equipment but does need to know how to turn off
the equipment and how to call for emergency assistance. This second
person must also agree ahead of time to perform such duties should the
need arise. Establish a check-in and check-out protocol.
- Ensure that all machine and
tool guards are installed in place, in good working order, properly
adjusted, and most importantly, used for their intended purpose. This
includes the use of chip shields for any drilling or cutting operations.
- Wear, at a minimum, safety glasses with side shields while in the
vicinity of operating machine tools. This applies both to workers and to visitors. Wear
face shields or goggles as required by work authorization for specific operations.
- Wear substantial closed-toe footwear of sturdy
construction, made of leather or other heavy, solvent-resistant material.
Wear approved safety shoes meeting ANSI Z74.1 when there is a risk of crushing
or piercing. Prohibit personnel, including visitors, from entering the
work area with sandals or open-toed shoes.
- Wear appropriate clothing.
- Wear hearing protection
and/or respiratory protection as required by work authorization for
operations that generate harmful noise, or airborne emissions. Contact
the Industrial Hygiene Group for assistance in determining which
operations require such protection.
- Do not use audio equipment
that obstructs the ear canal (e.g., iPods) or cell phone Bluetooth
headsets while operating machine or power tools. Such devices distract
the operator and can prevent him or her from hearing sounds that could
provide warning of an unusual operating condition or someone calling out
for assistance.
- Prohibit personnel under the
age of 18 from operating any machine or power tools unless the work is
part of a state-approved apprenticeship program.
- Tie back or otherwise secure
long hair; cuff or roll up long sleeves, and remove or tape down loose
jewelry when working with rotating machinery.
- Do not prepare or consume
food or beverages in areas where hazardous materials (including oils,
solvents, chemicals, cuttings, filings, and sawdust) are handled or
generated. Designate a food and drink preparation/consumption area, if
necessary, in an area that is kept free of hazardous materials at all
times.
- Where applicable, secure and
clamp down work pieces in work-holding devices and machines, preventing the
work from being lifted or dislodged.
- Use appropriate push sticks
or other approved methods as indicated in the work authorization to keep
hands and fingers well away from moving or rotating cutters, blades, and
other points of operation.
- Turn off the machine before
using a brush or wooden dowel (not hands!) to remove chips from the
machining area. Chips are not only very sharp but can be hot and can snag.
- Maintain good housekeeping. Work is not complete until
cleanup is done. Debris, coolants, and lubricants put workers at risk of
cuts or slipping, and can be a skin irritant. Clean up the work area with
a broom, brush, and dustpan, and clean up all spills with absorbents
and/or degreasers. Avoid using compressed air to blow chips off
machinery. Not only is this a hazard to the eyes, it forces material into
the precision inner workings of the machine and often distributes coolant,
oil, and chips over a larger area. Clean up the machine and sweep the
floor area of any remaining chips. Contact the Facilities Division for
assistance in removing oily buildup from floors.
- Line management in the
division in which the shop is located must ensure that all shop work is
monitored by a qualified shop manager. Contact Occupational Safety Group
personnel to help determine which individuals are qualified to serve as
shop managers. Post the shop manager’s name at the entrance to the shop. The
qualified shop manager must:
- demonstrate experience in the safe operation and maintenance of machine
and power tools;
- determine whether other personnel are qualified to operate specific
machine and power tools in the shop;
- determine who may use the shop machine and power tools, and how and
when they may do so;
- ensure that only qualified and authorized personnel operate the shop
machine and power tools.
- Permit only personnel who
have been explicitly approved by the shop manager and authorized by line
management to operate the equipment in the shop.
25.10.1 Safety Rules for the Use and
Maintenance of Laboratory-Specific Machine Equipment
The following rules apply to Laboratory-specific machine equipment.
- Ensure appropriate guards are in place, and create a safe operation/maintenance
procedure (JHA or AHJ) as applicable for Laboratory-made equipment. Examples
of hazards that require guarding include points of operation where personnel
can be pinched, nipped, crushed, burned, or cut, such as in presses, heat
sealers, polishers, rock-cutting equipment, and rotating transmission
components such as belt drives, gears, and rotating shafts over 10 rpm.
- Verify appropriate guarding, and follow manufacturer’s operation and
maintenance procedures for procured equipment.
- Permit only authorized and qualified personnel to operate laboratory
equipment when there is potential for exposure to injury (e.g., where guarding
or other controls can be easily defeated.
- Formal authorization, such as a JHA or AHD, is required for laboratory
equipment that exposes personnel to injury. Examples include centrifuges
without interlocking lids, microtomes, high-torque mechanical stirrers, and
unguarded shaker tables.
- Laboratory equipment that cannot cause an injury requires neither
guarding nor formal authorization to operate. Examples include centrifuges
with interlocking lids, vortex mixers, mechanical stirrers, Rotovaps, guarded
vacuum pumps, and guarded orbital shaker tables.
- Wear PPE appropriate for the hazard (e.g., lab coats, safety glasses,
goggles, face shields, gloves, long pants, closed-toe shoes, etc.). Contact
the Occupational Safety Group if you are unsure of PPE requirements.
- Permit only qualified and authorized personnel or vendors to repair or
otherwise service laboratory equipment.
25.10.2 Safety Rules for Use and Maintenance
of Office Machine Equipment
The following rules apply to office-specific machine equipment.
- Verify appropriate guarding, and follow the manufacturer’s operation and
maintenance procedures for procured equipment. Examples of required guarding
include paper-cutter guards and copy-machine interlocks, which prevent the
machine from operating when doors are open.
- Ensure that salvaged equipment has all the appropriate guards in place.
Contact the Occupational Safety Group if you are not sure.
- Office equipment commonly used by the public does not require formal
authorization to operate.
- Permit only qualified and authorized personnel or vendors to repair or
otherwise service office equipment.
25.11 Responsible Parties
25.11.1
Division Directors
LBNL division directors are responsible
for identifying:
- a home division responsible
person for each shop/lab, and
- qualified shop managers for each
shop under their responsibility
25.11.2 Supervisors, Work Leaders, and
Shop Managers
Supervisors, work leaders, and shop managers are responsible for:
·
ensuring that all requirements of this chapter are implemented
for machine tool, machine equipment, and power tool operation, maintenance, and
repair under their control;
·
enforcing safe machine tool, machine equipment, and power tool operation
and maintenance; and
·
removing from service, labeling, and securing any equipment/tool
that is damaged, in disrepair, or deemed unsafe.
25.11.3 Employees and Other Machine Tool,
Machine Equipment, and Power Tool Users
Responsibility for all machine tool use is shared between the supervisor and
the operator.
Employees and other machine tool, machine equipment, and power tool users
are responsible for observing all established safety regulations relating to machine
tool, machine equipment, and power tool operation and maintenance. They are
also responsible for:
- Operating and/or maintaining machine tools, machine
equipment, or power tools only if they are qualified and authorized
to do so.
- Adhering to all applicable safety requirements, rules, and
regulations.
- Providing suggestions on improving safeguarding that may
already be in place.
- Reporting any machine or tool that is not functioning
properly or that does not have a safeguard for all points of operation or
rotational motion; nip points; and cutting, shearing, punching, and forming
mechanisms.
- Wearing appropriate clothing when performing a job (for
example, covering skin where necessary, wearing no loose-fitting clothing
or jewelry near rotating equipment, and wearing suitably heavy shoes).
- Operating machine and power tools safely, and maintaining machine
tools, machine equipment, and power tools in good mechanical and operating
condition.
- Immediately reporting any machine or tool that exhibits
signs of excessive wear or has damaged or misused parts (e.g., a lathe
that is leaking an excessive amount of oil, or a drill press that appears
to have a faulty chuck that does not secure the tool).
25.12 Standards
OSHA 29 CFR 1910, Occupational Safety and Health
Standards for General Industry
·
1910 Subpart O—Machinery and Machine Guarding
·
1910 Subpart P—Hand and Portable Powered Tools and Other Handheld
Equipment
OSHA 29 CFR 1926, Safety and Health Regulations for
Construction
25.13 Related
PUB-3000 Chapters
25.14 Appendices
Appendix A. Application to Use Shop Equipment
Appendix B. LBNL Non-Laboratory Machine Guarding Requirements
Appendix C. LBNL Laboratory Machine Equipment Guarding Requirements