Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine mechanical hazards.
If your company is in the manufacturing sector, your employees likely face mechanical hazards, including the risk of amputation, from operating, cleaning, maintaining, or repairing equipment or machinery.
Last September, the Occupational Safety and Health Administration (OSHA) unveiled its annual “Top 10” list of its most cited standards at the National Safety Council’s (NSC) Safety Congress & Expo. While OSHA’s construction industry fall protection standard topped the list, two mechanical safety standards—lockout/tagout (control of hazardous energy) and machine guarding—made the Top 10.
The lockout/tagout standard (29 Code of Federal Regulations (CFR) §1910.147) was the fifth most cited in fiscal year (FY) 2024, with 2,443 violations. Machine guarding (§1910.212) was the 10th most cited, with 1,541 violations.
The lockout/tagout standard protects workers from machine hazards while machines are being cleaned, maintained, or repaired. The federal machine guarding standard protects operators and their coworkers from hazards associated with machines in operation, including flying chips, sparks, and moving parts.
Beyond just issuing citations and penalties, OSHA reaches settlement agreements with employers to resolve machine hazards.
Last year, Pepsi Guam Bottling agreed to pay $132,591 in OSHA penalties to settle safety and health citations for exposing employees to amputation and other serious injuries. OSHA had cited Pepsi Guam Bottling with one willful violation, one repeat violation, and six serious violations of machine safety procedures after an inspection found that the employer had disabled safety devices, allowing workers to reach into a bottle-labeling machine as often as 15 times an hour to grab and fix labels and adjust tipping bottles to avoid slowing or stopping production. Pepsi Guam Bottling agreed to abate the safety hazards; develop a written, comprehensive safety and health program; allow warrantless OSHA inspections; and form a safety and health committee of managers and employees.
Last spring, a Camden, New Jersey, auto recycler and auto parts supplier agreed to pay $868,628 in OSHA fines in a settlement agreement resolving violations that included inadequate machine lockout/tagout procedures and not protecting workers from machine operation hazards. The employer agreed to implement a comprehensive corporate safety and health management system consistent with OSHA’s guidelines.
The company also agreed to the following:
- Multiple facility safety audits by a third-party consultant;
- Safety training programs based on the audit findings; and
- Multiple opportunities for workers to participate in safety efforts without fear of retaliation, including a safety management committee that would review audit findings and evaluate the progress of the company’s safety programs.
The company purchases more than 7,000 cars and trucks each month for dismantling and has parts pickup locations in Baltimore, Maryland; Bayonne, New Jersey; and Brooklyn, New York, as well as sells parts online for shipment to buyers nationwide.
Last summer, a poultry processor settled with OSHA and the Department of Labor’s (DOL) Wage and Hour division to resolve safety and child labor violations at its Hattiesburg, Mississippi, facility.
In July 2023, a teenage janitorial worker was fatally injured at the Hattiesburg facility after becoming caught in a machine while cleaning it. The company agreed to take several steps to control machine hazards at the facility, including:
- Adding another properly trained supervisor to the sanitation shift.
- Providing workers who are exposed to lockout/tagout and machine guarding hazards with updated training.
- Requiring the plant’s manager and safety director to complete OSHA’s 30-hour general industry training and plant supervisors to complete OSHA’s 10-hour training.
- Instituting a system for assigning, identifying, and issuing locks to authorized employees performing lockout/tagout functions, as well as updating programs and training to reflect this requirement.
- Conducting a risk and hazard assessment to evaluate the safety exposures and hazards associated with current lockout/tagout procedures for the sanitation shift. The assessment must include a review of any incidents, including “near misses,” injuries, and unexpected start-ups or malfunctions of machinery.
- Performing monthly lockout/tagout safety audits for the sanitation shift for one year and providing proof to OSHA, including what steps the employer is taking to reduce hazards in response to the audits.
With processing plants, feed mills, and hatcheries in Alabama, Georgia, and Mississippi, the company produces 2 million birds and 8,500 tons of feed per week, shipping worldwide, primarily to the food service industry.
Equipment and machinery hazards pose risks that include injury, amputation, and death. During last year’s Safety Congress & Expo, the NSC offered conference attendees a look at U.S. Bureau of Labor Statistics (BLS) data for fatal and nonfatal worker injuries related to the Top 10 OSHA standards. Workers’ being caught in running equipment or machinery during maintenance or cleaning led to 54 deaths in 2022 and nearly 18,000 days away, restricted, or transferred (DART) from 2021 to 2022. Exposure to electricity led to 145 deaths in 2022 and nearly 4,000 DART cases from 2021 to 2022.
Workers’ being caught in running equipment or machinery during regular operation resulted in 35 deaths in 2022 and almost 27,000 DART cases from 2021 to 2022.
Machine and equipment hazards can also result in medical and lost wages claims. In a recent report of injuries and illnesses that lead to employers’ highest workers’ compensation costs, insurer Liberty found that body parts’ becoming “caught in or compressed by equipment or objects” (such as running machines or equipment) cost employers $2.05 billion annually.
Meat processing, manufacturing industries targeted by OSHA
OSHA has an ongoing National Emphasis Program (NEP), which was issued in 2019 to address amputation hazards in several manufacturing industries. The NEP targets sectors like fabricated metal products, food, and machinery. The amputations NEP focuses on compliance with the lockout/tagout and machine guarding standards, as well as the federal standards for woodworking machinery (§1910.213), mechanical power presses (§1910.217), and mechanical power-transmission apparatus (§1910.219).
In 2023, OSHA introduced an “instance-by-instance” enforcement policy, allowing for multiple citations for serious violations, including those involving the lockout/tagout and machine guarding standards. The policy imposes stricter penalties on employers.
“Inspection Guidance for Animal Slaughtering and Processing Establishments,” which is updated OSHA inspection guidelines for meat processing that were issued last fall, aims to address occupational hazards in the meat processing industry through outreach and enforcement. Meat and poultry workers experience serious injuries at twice the rate of other industries, with occupational illness cases significantly higher in the sector. Carpal tunnel syndrome rates in the industry exceed the national average by more than seven times. Other workplace hazards in meat processing include dangerous machinery, as well as high noise levels and exposure to hazardous chemicals. OSHA also noted an increase in child labor to clean machinery in meat and poultry processing facilities and prioritized inspections related to sanitation, ergonomics, and machine safety.
Besides the national program of outreach and enforcement to prevent amputations, OSHA has local and regional emphasis programs (REP) that include a focus on mechanical hazards in meat or poultry processing and manufacturing facilities, such as:
- Atlanta REPs for motor vehicle parts manufacturing and poultry processing;
- A Chicago REP for wood pallet manufacturing and a food manufacturing REP in Illinois, Ohio, and Wisconsin;
- A Dallas office poultry processing REP;
- A Nebraska local emphasis program (LEP) for meat processing out of OSHA’s Kansas City regional office;
- A Denver REP for wood manufacturing and processing; and
- A San Francisco office amputations REP.
From 2014 to 2020, the agency investigated multiple fatalities and severe injuries in Wisconsin’s food production facilities, uncovering significant violations related to machine safety and hazardous energy control. OSHA found that food production workers face a nearly 24 percent higher injury rate compared with other production workers in the state.
Your lockout/tagout and machine guarding compliance
Complying with OSHA’s lockout/tagout and machine guarding standards will help ensure worker safety, preventing amputations and other injuries. You must establish comprehensive procedures and a training program to protect workers from machine-related injuries.
OSHA’s lockout/tagout standard protects workers from serious hazards like amputation, burns, and electrocution by requiring formal practices and procedures for disabling equipment during cleaning, maintenance, and repair. To protect workers, machines must be de-energized, locked out to prevent an accidental restart, and tagged by the worker or supervisor locking out the machine or equipment.
Your lockout/tagout training must cover energy control (lockout/tagout) procedures and emphasize the prohibition against restarting locked or tagged-out equipment, ensuring both your own employees and contract employees are properly trained and informed.
Procedures for tagging out machinery must be developed, implemented, and enforced for any equipment or machinery that can’t be locked out. You must train workers on tagout procedures, conduct regular retraining, and ensure all equipment that can be safely locked out is de-energized and locked.
Your employees who are authorized to lock out machines or equipment for cleaning, maintenance, repair, or service must be trained to recognize all sources of hazardous energy in your facility. They must know the type and magnitude of energy found in your facility and the means and methods of isolating and/or controlling energy as part of your company’s lockout/tagout procedures.
Your employees should only use the lockout/tagout devices authorized for specific equipment or machinery in your facility. Lockout/tagout devices must be durable, standardized, and substantial, and tags must identify the individual who locked out or tagged out a machine or piece of equipment.
Machine guarding devices include barrier guards, light curtains, and two-hand operating devices and should be securely attached to machinery. Alternative placements are allowed when direct attachment isn’t feasible. For example, revolving barrels, containers, and drums may be guarded by an enclosure that interlocks with the drive mechanism, ensuring machinery can’t operate unless the guard enclosure is in place.
Machines must be designed to prevent any part of an operator’s or other employee’s body from entering danger zones during operation. Specific machines, such as guillotine cutters and milling machines, require point-of-operation guarding to enhance safety, and any special hand tools used should facilitate safe material handling without exposing workers’ hands to machine hazards.
Ensure you’re taking steps to protect your employees from equipment and machine hazards both during normal operation with machine guarding and during cleaning, maintenance, and repair with lockout/tagout devices, procedures, and training. Physical machine hazards include amputation, burns, and electrocution, as well as crushed, cut, fractured, or lacerated body parts. Remember that worker injuries from being caught in equipment or machines can generate hefty workers’ compensation claims for medical reimbursement and lost wages.