Best Practices for Band Saw Safety
By Adele L. Abrams, Esq., CMSP
For a number of years, OSHA has taken aim at amputation hazards across many industries, including pallet manufacturers and companies that disassemble pallets. In 2002, OSHA’s initial amputation National Emphasis Program (NEP) was expanded to cover a variety of machine types associated with this hazard. The NEP was renewed in 2006 and still is a major trigger for inspections of pallet facilities.
Moreover, with the new injury reporting requirements that took effect on January 1, 2015, in federal OSHA states, employers must notify OSHA within 24 hours of any amputation (full or partial), loss of an eye, or other injury that requires in-patient hospitalization. State plan states will have until early next year to comply, although some states have already adopted their version of the requirements. So far, about 60 percent of establishments filing such reports are visited by OSHA for a full-blown incident investigation, while the remainder must complete a “Rapid Response Letter” within 5 calendar days or they too will be inspected.
The convergence of these two programs has put band saw safety back in the spotlight for pallet companies because this equipment has historically been the source of serious workplace injuries. During the 1990s, the wooden pallet manufacturing industry experienced a much greater than average overall rate of non-fatal injuries (288 percent higher than average) and an even worse rate of amputations (1317 percent higher than average), cuts and punctures (818 percent higher than average). Even with the progress made over the past several decades – including a period in the George W. Bush administration when NWPCA had an alliance with OSHA to work on improvements in this area – band saws will still come under scrutiny during OSHA routine inspections, NEP-based inspections and in accident investigations.
A study by the National Institute for Occupational Safety and Health (NIOSH) more than a decade ago, which arose from an alliance with NWPCA, led to recommendations on how best to protect workers, and efforts are ongoing.
There are a variety of types of sawing equipment used in the pallet industry sector, including band saws and re-saws, circular saws, table saws and radial arm saws. While some of this equipment comes equipped with manufacturer-installed guards, others are not designed in this manner because of feasibility issues. Sometimes, OSHA will challenge pallet companies to design their own guards, but installing fabricated guards can itself interfere with the safe or efficient operation of the equipment and – moreover – can invalidate a manufacturer’s warranty because the pallet company has, in effect, “redesigned” the equipment and therefore assumes more liability for its failure or misuse.
When approaching OSHA on this issue in the previous administration, NWPCA took the position that, by following recommended “best practices,” employees can work safely around such potentially hazardous equipment without installing point-of-contact guards. After development of the best practices through the previous OSHA/NWPCA alliance, the salvo of citations ceased for the most part but, in the current administration, isolated enforcement actions have occurred concerning equipment such as dismantling machinery under one of OSHA’s machine guarding standards (e.g., 29 CFR 1910.212 and 1910.213).
Generally, the matters have been resolved without the need for litigation or modification of equipment, but employers are well-served if they are familiar with these safety “SOPs” in advance of an OSHA visit, train employees on the safe work practices, and document such training. In addition, if manufacturers have warning decals (preferably bilingual to better inform diverse workforces), employers should utilize those prominently on equipment to reinforce safety training and work rules.
There are two types of machinery hazards: “point-of-operation” and “mechanical motion.” The types of safety controls typically utilized to mitigate such hazards include: guards, devices, location and distance, feeding and ejection methods, and miscellaneous aids. The problem is that there is no “one size fits all” solution because not only must each piece of equipment be evaluated for potential hazards, but the configuration of equipment within a plant can also be a factor as to what is compliant and what can trigger a citation.
For dismantling equipment, the point-of-operation situation is the most dangerous because this is where work is performed on the material being cut. These machines have moving components that can injure a worker in the area of motion and there are various types of motions to be analyzed: reciprocating motion, transverse motion, rotating motion, and nip points. Even if workers are keeping body parts such as fingers and hands clear from the cutting edge, workers can also be injured if their clothing, hair or jewelry gets caught in a moving part.
In addition, inspectors will consider other hazards associated with the operation of dismantling machines and band saws, including the hazard of being struck by flying material, and excessive noise resulting from machine operation. These hazards can be mitigated by strict enforcement of the use of safety goggles (with protective side panels) by those operating the machines, and use of appropriately-related hearing protection by not only the equipment operator but also by other workers who are in proximity to equipment that emits noise over 90 dBA over an eight-hour period.
OSHA’s preference is always going to be to install guards on the equipment to prevent contact with mechanical motion hazards, but inspectors can be convinced not to issue citations if they are satisfied with work procedures that can satisfactorily protect workers.
For band saws and dismantling equipment in the pallet industry, OSHA has been willing to accept the following work practices in lieu of guarding, for compliance purposes:
- Train workers not to place hands or other body parts within 12 inches of the saw blade of the machine;
- Etch or mark a line on the saw table at the 12-inch mark to give a visual indicator of the danger zone to workers;
- Require workers to use a “push stick” if pallets become jammed, so that hands are not used within 12 inches of the blade;
- If the equipment is operated by two employees, one should push the pallet from one end and the other should pull the piece from the other end after it is sawed or disassembled, and both workers must keep their appendages at least a foot away from the blade;
- If possible, lengthen tables to provide a greater safety zone, but also consider ergonomic factors that could result from such redesign, including back strains, and try to develop a solution to prevent substituting one type of injury for another (hint: a safety consultant may know of solutions that can reduce such exposures);
- If possible, install a cover above the blade at a height that allows pallets to pass beneath it, but ensure that the manufacturer does not object to the modification of the equipment for safety reasons; and,
- Warning decals with these work practices should be posted on the machine or in the immediate work area for quick reference by employees.
Of course, in addition to abiding by these work practices, any maintenance or repair of band saws and dismantling equipment should only be done after the equipment is properly de-energized, any stored hydraulic or pneumatic forces drained off, and the equipment is tagged/locked out.
Moreover, training and safe work practices presume that the employer “recognizes” the hazard and has created the work practices to protect workers from harm by the hazardous situation. If a hazard is known and not corrected, or if controls or work practices are implemented but then are discontinued, OSHA will issue willful citations that can result in $70,000 penalties for each affected worker, and can even criminally prosecute supervisors and owners in the event of a fatal accident.
Whatever practices are ultimately adopted by the employer as feasible for pallet operation equipment, employee training is critical and must be well-documented. If workers do not understand the safe work procedures, they are at high risk of injury. If workers fail to follow the safe work procedures after receiving appropriate training and supervision, they need to be disciplined. Unenforced rules are no rules at all.
(Article published in PalletCentral Magazine, July-August 2015)
Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and provides safety training and consultation. The Law Ofice of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV.