Punch Press Guarding a top
Priority During OSHA Inspections

In the April issue of Springs, I advised readers about OSHA’s new National Emphasis Program (NEP) on machinery that can cause amputations. This NEP, combined with the older NEP on punch press guarding, makes punch presses a real priority during OSHA inspections. Nearly every OSHA citation I review has cited some part of the punch press guarding standards, many with very high penalties.

Punch press guarding can be very complicated and confusing, depending on the type of press; types of air and/or electrical logic; and types of controls, guards, barriers and devices. The size of the punch press does not make a difference. Even the small bench presses are covered by the same guarding standards.

There is a misconception that if a punch press, either full or part revolution, is equipped with dual palm buttons, the point of operation does not have to be guarded. That is not necessarily true; it’s not that simple. It all depends on the type of press, type of brake/clutch assembly, anti-repeat mechanisms, brake monitors and control reliability features. It also depends on the distance the palm buttons are located from the nearest pinch point or point of operation. In many cases, the use of light curtains along with dual palm buttons is still not legal. Make sure your power punch presses are guarded properly. If you are unsure, consult an expert. Doing so could not only save you thousands of dollars in OSHA penalties, but even more important, it could prevent an amputation.

Part of OSHA’s special punch press emphasis is to inspect safety, maintenance and training records. Make certain you have formal documented programs and certified employee training records on the following areas:

• Weekly safety inspections.

• Monthly maintenance inspections.

• Brake monitor testing.

• Die setter training.

• Punch press operator training.

• Additional record keeping is required if you use pullbacks, restraints, light curtains or presence-sensing devices.

Other punch press requirements that are scrutinized during a typical OSHA inspection include the following:

• Barrier guarding.

• Cage and barrier interlocks.

• Lockout/tagout requirements.

• Spring-loaded turn-over bars, where required.

• Blocks for block-out.

• Belt and pulley guarding.

• Electrical power disconnect boxes that can only be locked in the “off” position.

• Motor starters.

• Single-stroke devices.

• Anti-repeat mechanisms.

• Foot pedal guards.

• Palm button guards.

• Press control “key” supervision.

• Lighting.

• Clearance around the press.

• Anchoring.

Jim’s Regulatory Tip

Be prepared for the OSHA “Hot Buttons.” Guarding and the new electrical safety standards that took effect on August 13, 2007 are top priority.

Both qualified and unqualified employees must be trained in electrical safety work practices. All qualified employees must have Personal Protective Equipment (PPE) assessments and training. Qualified employees include electricians, technicians and maintenance personnel.