PSDI on Mechanical Power Presses 1910.217(h)?
Does anyone have experience with 1910.217 Mechanical Power Presses? I ran one for a couple summers back in 1972 and 1973 while going to college. I remember the pull-back guards, and how my shoulders felt after only a few minutes. I vividly remember at the start of every shift the old Setup Guy would come over and adjust the cables for my 37” arms. As a stark reminder I always noted that he was missing two fingers on each hand. I had two 800-ton mechanical power presses in my area as a new supervisor when I started my career. However, since 1990 have mostly not been around them until now with a couple customers that have several.
One thing I noticed when I saw all these presses in that one thing has changed, they invented Presence Sensing Device Initiation (PSDI), especially light curtains! We sure didn’t have them back in the 70’s and 80’s.
I believe if I recall correctly in 1985 OSHA had 1910.17, but now a good share of it is devoted to PSDI so the standard is now longer. I noted some interesting requirements in 1910.217(h) which covers PDSI.
First, 1910.217(h)(1)(v) The PSDI mode of operation shall be used only for normal production operations. Die-setting and maintenance procedures shall comply with paragraphs (a) through (g) of this section and shall not be done in the PSDI mode.
This paragraph would tell us that you cannot use PSDI (Light Curtains) for the protection of employees working inside the bed of the press during setup and maintenance. Does not seem ambiguous at all. However, I know employees, seems like to me if management did not continually reinforce this, the employees would violate it
Second, 1910.217(h)(10)(ii) The following checks shall be made at the beginning of each shift and whenever a die change is made.
There are five tests to done in this paragraph (A)-(E). I would recommend if you required to do these it should be documented.
https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-O
My question to all of you is have you ever heard or known anyone to be cited by OSHA for anything in 1910.217(h), especially the above two paragraphs. I can locate how many times employers have been cited for 1910.217 but nothing more specific. Help?
Comments (9)
I have not heard of anyone specifically/personally, but do know KY OSHA has it posted as their #3 most cited violation for FY2022 for NAICS 332 (Fabricated Metal Product Manufacturing). Doesn't say which paragraph of the standard was cited, but does say 1910.217. It was #12 for all manufacturering NAICS codes (NAICS 33), too.
In a previous life, OSHA Enforcement Region 7, Power Press (High Hazard - National Emphasis Program) were regularly if not all the time being looked at on inspections. Power press inspections are difficult as each type is different by updates, guarding, and purpose. Specifically, the training received pointed inspectors to associate press operations as having:
1. Blocking available and accessible. Check the Maintenance procedures for including the block
2. Do the blocks have safety relays connected to them. When the block is pulled a rope or cable would disengage a key that would shut off power to the associated motor of the press itself.
3. Other blocking methods, insertion of a safety pin in the flywheel to lock it from movement. Or a safety pin in the actual piston driving the device or die.