PSDI Inspection, Maintenance, Certification/Validation?
I have customers that have large mechanical power presses, up to 1000 tons. These customers have all done an excellent job investing and installing Presence Sensing Devices Initiation (PSDI) systems, mostly Light Curtains and similar devices. I am always careful to confirm all points of operation, nip points, and power transmission are guarded safely, per 1910.212(a)(1). Mechanical Power Presses are the most dangerous machines in manufacturing. When the ram falls there is no power in the Universe, short of God, that will stop it smashing the dies into metal, or God forbid a part of a human.
I have been around Mechanical Power Presses for 50 years. I have dealt with all too many amputations on presses. I am in wonder today of the new PSDI systems, as I recall back in the 70s all we had were restraints and pull-backs! You cannot really appreciate PSDIs if you have not been strapped into pullbacks for 8 hours and how your shoulders and arms ache after! I learned working my way through college!
I remember hearing about the coming of PSDIs in the late 80s but never actually saw them. I left the forming business soon thereafter, only to reenter it again in the late 90s. By that time PSDI was universal except on small old presses. In those cases, we used two handed controls (buttons). I have not seen pullbacks in manufacturing in over 30 years. I have seen restraints a couple times.
It has taken me all that to get to my question. I was reading over 1910.217 Mechanical Power Presses. Like I said I have investigated amputations and dealt with OSHA because of them. The machines involved had PSDI. In all that time I have never seen anyone following 1910.217(h)(1) and (h)(11), concerning Inspection, Maintenance, and Certification/Validation of the PSDI. I have never even had an OSHA CSHO ask about these paragraphs in my cases as a site H&S Manager and we had several PSDI systems, some with amputations (lockout was always the root cause). Has anyone ever known OSHA or a state agency to write citations for not following these paragraphs or even asked about it?
I am trying to get ammunition to get my customers to follow these paragraphs. When I point them out, they just shrug their shoulders. If it comes to it, I am just going to give them a Memo, to cover my butt. Modern PSDIs are very reliable and have fast SIL levels, but they still may fail one in millions of cycles.
Thanks!
Comments (19)
That is correct and great Job Tom.
I've never seen it actually cited, but at my last employer, I oversaw a machine shop which had several MPPs and they were actually pretty strict on that stuff, involving engineering and maintenance in nearly every case.
One thing many people skip out on also is the OSHA reporting timeframe for point-of-operation injuries involving MPPs, which is 30 days. Most of those result in amputations, so would trigger the normal requirements (24 hours for federal OSHA, 72 hours for KY), but if it doesn't involve an amputation, it still has to be reported to your applicable OSHA office within 30 days of the injury.
Great topic and discussion, Tom!
I’m not familiar with those regs, but if that’s what OSHA is requiring then I think it’s totally valid to point it out. Thanks for sharing, I’m not familiar with presses, so this was good learning for me
@Tom Fitzgerald (wouldn't let me comment below). A degloving is where just the skin is removed on all sides of the finger. It's common for people wearing rings or when they get caught behind the knuckles and it just removes the skin, but not the bone. Degloving is a form of avulsion, so all deglovings are avulsions, but not all avulsions are deglovings.