Punch Press Lockout/ Tagout requirements 3

[Safetyranger]

We are a large manufacturer that uses literally hundreds of mechanical punch presses. They are 12 ton, foot pedal triggered models for the most part. We have a very detailed lockout tagout program complete with specific lockout procedures posted on each machine. There has been some debate on whether or not the machine should be locked out when a die is not in it. It is understood that lockout is required when removing or loading a die but the question is; should it be locked out when sitting empty. Any thoughts, ideas, sources?

 

[HEC]

I would ask "why not leave it locked out?" The next operation on the press is to load the next die (it will need to be isolated for that) or a maintenance service (it will need to be locked out for that). If testing is required the isolation can be lifted for testing then re isolated after testing.
If there is a question about leaving equipment isolated for long periods, such as some one has inadvertantly defeated isolation. The procedure must be, before starting work confirm isolation is still in place.
Does your isolation procedure include insertion of a chock under the platten?

Mark Hutton

 

[Safetyranger]

Keep in mind the basic rules of lockout tagout, only the individual applying the lockout device may remove it. It could be days before that individual is back on site. Also, we are talking about hundreds of presses. There are between shift lockout procedures, but they are a last resort; the idea is to avoid that scenario when possible. There is nothing amiss with the machine, it is simply not being utilized. The hazard is in the transfer. There is actually less hazard with the tooling removed as you have taken away the point of operation leaving only a 10" to 12" void with a platen that cycles about 2.5" of that. Nothing below it. The hazard has been removed, why isolate the machine? Would you lock out a drill press when there's no bit in it? This is a 50/50 judgement call and I've been unable to locate a source that specifically addresses it.

 

[HamishMcTavish]

Hi Safetyranger,

I'm not familiar with the 'basic rules' you refer to - surely your plant has a management process for tagouts? It seems unduly restrictive that the only person who can remove a tagout is the person placing it!

The key aspects must be that the isolated eqpt is inoperable / de-energised, the tag should have a reference as to when and WHY it was placed. As long as the operator procedures for use of the machine account for the sensible removal of tags i.e. once machine is established as fit for use (i.e. not under maintenance, withdrawn from service or linked with other upstream or downstream maintenance) and the operator has put in the next die according to their training / procedural checks then why shouldn't a different operator remove a tagout?

I have to say i agree with HEC - what is the problem leaving a machine tagged out? Apart from your 'rule' re tag removal it seems eminently sensible.

Question - what would your company do if the person who had placed a tag on (say) 100 machines suddenly got hit by a bus? Decide what you would do to untag the machines and then just make that part of your general management / operating processes.

Kind regards, HM

No more things should be presumed to exist than are absolutely necessary - William of Occam

 

[Safetyranger]

I believe we have a misunderstanding of what I'm looking for here. Our facility does not utilize tagout without a lock. If the key is left accessible to anyone other than who put the lock on, what is the point of locking out? Lockout/tagout is a system used to isolate hazardous energy during maintenance or tool changes. The fact that one operator can physically defeat a lockout imposed by another operator renders the program useless. It must physically prevent start up of that machine until the operator locking out is ready for it to start. We can put in work instructions all day long, but when someone looses an arm or hand to one of these machines, the fact that someone can be held accountable for going against work instructions won't matter much. We look at the program more from the angle of eliminating hazards than making it convenient. My question is; is it compliant to leave the "unloaded" press unlocked? Convenience and program specifics aside. Sources? Thank you for your input.

 

[HamishMcTavish]

Hi Safetyranger - i'm not suggesting that anyone should be able to defeat a lock / tag out - just that your processes for management of them should allow more than one person to release the tag / lock but in accordance with a controlled process.

RE Sources, you could try the following which are UK based codes of practice but you could look at the general principles.

http://www.hse.gov.uk/pubns/priced/hsg253.pdf

is the "good practice" for process plant isolations but the ideas should be similar to what you want

you could also look at

http://www.hse.gov.uk/pubns/priced/hsg250.pdf

which is the guidance for permit to work systems

Regards, HM

No more things should be presumed to exist than are absolutely necessary - William of Occam

 

[safetydan]

I don't know what country you are located, but in the US, lockout/tagout(LOTO) must be used when performing service and maintenance on a machine. Specifically, if you are removing a die from the press or installing a die, then the press must be locked out. Concurrently, if you are working on the press regardless of a die or not, the machine must be locked out to prevent accidental start-up. If you are simply turning the machine off once the work is complete and not using it until the next production run, LOTO is not needed. LOTO is solely for the prevention of accidental start-up or release of stored energy during maintenance and servicing operations only.

On a side note, I would be very concerned about your initial statement about your punch presses being foot activated. Do you have some other form of guarding to prevent operators from putting their hands into the point of operation? OSHA is very specific in their operation requirements for mechanical power presses(including punch presses). Also, OSHA is in the early stages of developing new regulations for all presses so be aware of future changes.

 

[Safetyranger]

You have just reinforced my initial instinct that there is no reason to lock them out when sitting unused without a die in them. There has been some debate. Again, my thoughts were that they need not remain locked out when unloaded; only when loading, unloading, or servicing.
As to the side note. We have machinists dedicated solely to guarding 40+ hours per week. The guards on our dies are specifically designed to admit the material only (profile cut-outs). No room left for body parts. In addition to that, all pedals are fitted with the correct cover to prevent accidental trip. Some of the materials that we punch are quite large so two hand trip mechanisms aren't practical without radical workstation design changes. The operations that can be converted to a two hand trip or similar controls have been. We very recently completed an OSHA inspection (still waiting the report in fact) so we'll get it first hand very soon if we aren't compliant in that area. From the inspectors' at the time of the audit, the guarding was more than sufficient.

 

[HEC]

Been busy on other items lately! Safetyranger I am quite familliar with the LOTO systems where a tag can only be removed by the person applying it. I apreciate the issues associated with that. My suggestion is to realy to leave the equipment in an isolated state perhaps with out a tag on it or with a status tag to advise power/control has been isolated. The nex person to work on the equipment only has to confirm isolation and tag onto the appropriate points.

Mark Hutton

 

[safetyguy3]

I joined this forum just to answer this question. Sorry if it is late, but at least all that read it from now on will know the answer.

The OSHA regulation 1910.147(c)(5)(ii) states "Lockout devices and tagout devices shall be singularly identified; shall be the only devices(s) used for controlling energy; shall not be used for other purposes"

What this means is that you may only use a company supplied lock for locking out a machine. Conversely this lock may only be used for locking out a machine and not for anything else, as it states at the end of that rule. Since the machine is not techinically being locked out for the machine to be worked on, you may not use a lock out lock on it.

Here is an OSHA letter of interpretation about this subject.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25538

Hope this helps.

 

[Safetyranger]

THANK YOU Safetyguy3!

This is exactly what I was looking for. I believe some international rules may differ from OSHA on some of the finer points of this subject. I looked for quite a while for a letter of interpretation on the subject and could not find one. We did make the rule, incidentally, that LOTO is not to be used for a machine that is simply sitting unused or unloaded unless that condition creates a specific hazard. It was determined in-house that an unloaded punch press creates less hazard than a loaded press (which is not locked out when not in use) so they are simply left turned off.