1910.217(e)(1) Mechanical Power Press Inspection
Hello
Trying to create an inspection checklist for our foot operated full revolution clutch punch press. It’s a small old Bliss press thats been fitted with a die to manually punch holes in a small stack of paper that the operator uses both hands to feed in under a guard at the point of operation. I was able to put together an inspection checklist but am having trouble determining the frequency of inspections.
1910.217(e)(1) states: Inspection and maintenance records. The employer shall establish and follow an inspection program having a general component and a directed component.
Can someone explain the differences between a general component and a directed component inspection program? I see that there is a difference of periodic and regular inspections (e)1(i) A vs. inspect and test each press on a regular basis at least once a week (e)1(ii) A. Parts B and C seem have subtle wording differences but seem to be saying essentially the same thing.
Thanks
Comments (5)
Not my area of expertise as I'm in construction, but when I get into the weeds on interpreting things which happens often because I over think things:
1. Can you find the definition of general and directed component? Usually the definition are listed at the beginning of the standard.
2. In the body of the web page online, at times, you'll see a color blue on the citation number which is a hyper link. This leads to standard letters of interpretations which are questions from people sent into OSHA. That may lead you somewhere.
Below is from the federal register (link at the bottom):
"This direct final rule revises paragraphs (e)(1)(i) and (e)(1)(ii) of OSHA's Mechanical Power Presses Standard at 29 CFR 1910.217. This rulemaking also reorganized the paragraphs by dividing the requirements into discrete provisions, and redrafted the provisions in plain language to make them easier to understand than the existing provisions. The first two provisions, paragraphs (e)(1)(i) and (e)(1)(ii), cover periodic and weekly tasks associated with the mechanical power-press inspection program. To further delineate the tasks covered by these two provisions, OSHA refers to the requirements of paragraph (e)(1)(i) as the "general component of the inspection program," and to the requirements of paragraph (e)(1)(ii) as the "directed component of the inspection program." In this regard, the requirements of paragraph (e)(1)(i), the general component of the inspection program, cover all parts of the equipment and stipulate a nonspecific interval ("periodic") for meeting these requirements. However, the requirements of paragraph (e)(1)(ii), the directed component of the inspection program, address specific parts of the equipment and define the frequency employers must follow when inspecting and testing these parts ("at least once a week"). OSHA believes these revisions will assist the regulated community in differentiating the requirements of these provisions."
https://www.osha.gov/laws-regs/federalregister/2013-11-20-0
What kind of guarding does the Bliss have?
One of my best days in the corporate world was the day we sent our last Bliss to the scrap yard to be made into boat anchors! Nothing would have made me happier than to put it in the arc furnace myself! A Bliss was the first machine I ever operated the day after high school graduation (in 1972). It had pull back guards. As the set-up man adjusted the guards I saw he himself was missing two fingers on each hand. And as I looked around saw three other employees with missing fingers! The setup guy saw me and warned me how dangerous the machine was! He told me later that summer that they are the most dangerous machines man ever made to work metal! Nothing in the 50 years since has made me doubt his words!
Well I thought in 2007 I would never have to worry about them again. But I became a consultant and they have come back to haunt me! I now have customers with them. The only difference is I have not seen any pull back guards in many many years. most have PSDI guarding now (light curtains - mostly)!
One of my customers even has scarier machines, Brake Presses! The employers hold steel pieces 1/4" from the point-of-operation! The first time I saw them running, it took my breath away. Then I noticed they had put duct tape over the PSDI!!!!! I yelled, "STOP!" Then went to the Plant Manager and told them if they insisted on running those machines like that, I was DONE!!!!! To their credit they promptly purchased new laser guarding which works great!
Did I say I do not like Mechanical Presses? I hate them and their cousins, Brake Presses!
Thanks for the replies. The guard is a simple piece of plastic mounted to the gib that covers the point of operation and allows the operator to insert a small stack of paper at the bottom using (hopefully) two hands. No light curtain (can’t use one on a full revolution press), pullbacks, or other safety devices and since it’s foot operated there are no two hand controls. It probably needs guards on the sides as well as an operator could reach in to clear a jam while the press is still running.
Based on what the directed component section says I will be inspecting the press once a week. I understand “general” vs “directed” components and that directed is intended to be more specific to the clutch/brake mechanism, anti-repeat, and single stroke, but it seems to me that they are overcomplicating it as they also mention those components in the general section.