By Ruth Kiefer, MSc, ARM, Loss Control Manager

Many of our manufactures and policyholders may or may not know we also have been servicing the printing industry for a few years now. During this time I have been asked on numerous occasions what does MIOSHA compliance look for in our industry? During one of our recent training events with MIOSHA, I had the opportunity to inquire about which standards MIOSHA refers to when they conduct a compliance visit in a Printing facility.

Having seen most of our workers’ compensation injuries related to inadequate LOTO (Lockout Tagout) procedures and where the majority of our members have the most questions; I directed our conversation to the LOTO requirements and what they are looking for. What I found out was in the 1990’s OSHA and ANSI came together as a board to interpret and clarify what actually applies to the printing industry, since there are a variety of printing presses with different technologies, and most of them spanning many years.

In addition to the locking out of equipment, they also defined what was considered “minor servicing”, which includes clearing paper jams, minor cleaning, lubricating and adjusting operations, certain plate and blanket changing tasks; and in some cases, paper webbing and paper roll changing. So in a nutshell, your workplace hazard analysis on each piece of printing equipment, will determine those tasks or operations that can be safely accomplished by your employees.

The exception to “minor servicing”, and where the LOTO comes into play is when the employee has to remove a guard or unjam something in the point of operation. So I asked for more clarification of what they were looking for. The former compliance officer sent me a copy of the settlement agreement and highlights what compliance officers are specifically looking for regarding Part 85 and what printers need to have in place to comply with Part 85. If a hazard is observed during a visit, they are directed to document it and cite it. Listed below are the 16 key points they are addressing with regards to your printing equipment.

• The electronic safety device will only be used in minor servicing activities that are routine, repetitive, and integral to the use of the equipment for production, such as plating up, blanket washing, and webbing.
• In all other instances involving repair or maintenance of the presses, a lockout procedure will be used.
• All affected employees will be trained on the use of the “safe” system, as well as the lockout procedure.
• A written “safe” procedure has been developed and disseminated to employees.
• The safe procedure requires that the safe be engaged on each machine when an employee performs any servicing on it and that no employee is to take off a safe engaged by another employee.
• The safety controls are push buttons, located on the operating parts of the press. Sufficient push-button stations are placed so that the operator always has access to the button. The safe buttons will be of a fail-safe design and color-coded.
• The safety controls, once engaged, can only be taken off at the unit where they were pushed in.
• There will also be a stop button that stops the press regardless of speed. This stop button takes precedence over all control functions.
• The safety controls are connected to the press so that no unit of the press can be operated if only one safety control is engaged. The pushing of a safe button at any station prevents starting or moving the press from any other station.
• Where there are several units that have to be mechanically as well as electronically connected, the safety control system will be configured so that even where there is an error in connecting the units electronically or mechanically, the engaging of the safety control will prevent the start of the press.
• All units will be equipped with a finger bar at the pinch point that stays in place when the operations covered by the procedure are being performed.
• Each operating unit will have a lighting system indicating that the safety control button has been engaged at that station. A second light indicates that a safety control button has been engaged on the press. A third light indicates that all safety control buttons have been disengaged and the press is ready to use.
• Each press will include a built-in audio signal that will be alternated for every other press so that two presses in immediate proximity will not have the same warning sound.
• When the inch button is pressed after all safes are taken off, the audio signal will sound, indicating that the unit is about to move. This signal will sound at least two seconds before the press will move.
• The inch buttons are designed so that in order to keep the press moving in the inch position, the inch button must be continually depressed. If the button is released, the press will stop.
• Once the plating up or other operation is complete, the procedure will call for the employee to take off his safety control and to step out of the unit. The press will be brought up to full run speed by a designated operator at a button station where two buttons must be depressed to prevent accidental startup.

The above may be a tall order or even a bit confusing due to the various ages of equipment used in your industry. From my own personal experience, as a former graphic artist in the mid to late 80’s, the printing industry has come a very long way from the days of manual type setting, platemaking, and other offset printing practices. So please feel free to contact your loss control representative or me if you would like further information on how to complete a workplace hazard assessment, or a review of your LOTO program so that we may answer any questions you might have regarding the above requirements.