Keeping workers safe is a crucial part of a successful metalcasting operation. Though foundries are safer than ever, precautions still need to be taken to make sure everybody can work in a clean and protected environment.

“Compliance to OSHA regulations is the absolute minimum expectation of an employer in regards to safety,” said safety expert Ted Schorn, vice president of quality and technology, Enkei America (Columbus, Indiana). “Actions above and beyond compliance are related to things like understanding and preventing identified hazards via risk analysis techniques, utilizing employee engagement strategies to drive behavior-based safety and creating a safety-minded culture from the top down that demonstrates safety is more important than anything else.”

OSHA creates regulations and standards, and some, like the use of PPE or the lowering of silica, are discussed almost daily. Other regulations, however, are equally important but can be overlooked or de-emphasized. The regulations, both well-known and obscure, can be intimidating and written in dense legal language. They have many different sections, sub-sections and sub-sub-sub sections, and it makes it seem virtually impossible to keep employees safe.

“At the end of the day, OSHA requirements embody our best understanding of the proper way to protect workers,” Schorn said. “They have been created in a very administrative-heavy legal process and only address objective things that are required for the minimum protection.”

Following are 10 OSHA standards that may have been forgotten but OSHA commonly cites, so metalcasters need to include them in their safety plans and employee training.

1. Ladders (1910.23)
On the surface, you would think ladder safety is a relatively simple regulation. But it’s not, as OSHA has a lengthy and detailed set of rules for manufacturers to follow.
Among the general requirements for ladders, the employer must make sure they are inspected prior to every use and the maximum load must be visible on each ladder.  When reaching sideways, employees must not allow their center (belt buckle) to go beyond the side rail of the ladder.  When setting up an extension ladder, the feet should be 1 ft. from the wall for each 4 ft. of rise.  

Many more regulations cover subjects such as selecting the proper ladder for each job, placement, corrosion resistance, inspection timelines, the proper way to mount and dismount, and even that employees must face the ladder when climbing up and down. OSHA also offers guidelines on stepladders and step stools.

2. Permit Required Confined Spaces (1910.146)
Per OSHA, this “section contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces.” A confined space is any space that is large enough for the whole body to enter, hinders entry and exit, and is not designed for continuous occupancy.  Examples include sewers, tanks, industrial ovens, some CNC machines, sump pits, silos, and water towers.

The section says the “employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces” and that “If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces.”  Employers must prohibit employee entry allowing only employees who have been trained, have the proper equipment, and are accompanied by those trained in confined space rescue.

This section also lists the regulations on guarding confined spaces, ventilation, testing, and how to reclassify permit-required confined spaces as non-permit.

3. Control of Hazardous Energy (1910.147)  
The Control of Hazardous Energy, often referred to as LockOut/TagOut, requires that equipment be de-energized before maintenance or other work occurs on the equipment. 

The objective is to prevent injury when equipment unexpectedly starts up or moves due to the release of stored energy.  The regulations require that procedures be developed for each piece of equipment to ensure sources of electrical, mechanical, hydraulic, gas, steam, gravitational, spring-loaded, or pneumatic energy are discharged and disengaged or blocked.

For an energy control program, OSHA requires an “employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.”

The Control of Hazardous Energy section also includes information on energy control equipment procedures for lockout and tagout devices, and training so all employees understand the energy control program.

4. Fire Extinguishers (Portable Fire Suppression) (1910.157)
The section refers to the “the placement, use, maintenance, and testing of portable fire extinguishers provided for the use of employees.”

One of the key parts of the rule is OSHA’s requirement that the “employer shall provide portable fire extinguishers and shall mount, locate and identify them so that they are readily accessible to employees without subjecting the employees to possible injury.” One thing employers cannot do is “provide or make available in the workplace portable fire extinguishers using carbon tetrachloride or chlorobromomethane extinguishing agents.” Meanwhile, they must “assure that portable fire extinguishers are maintained in a fully charged and operable condition and kept in their designated places at all times except during use.”

The section on fire extinguishers has information on how far employees can be from extinguishers, who is responsible for maintenance and testing, and how employees can be temporarily protected when the extinguishers are removed for testing.

5. Forklifts (Powered Industrial Trucks) (1910.178)
Section 1910.178 covers “safety requirements relating to fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. Forklift operators must receive classroom training and hands on training before they operate a forklift and at least every three years. Forklifts must also be inspected before use, at the start of every shift.

The section has many rules and guidelines describing when and where industrial trucks can be used. There are also explanations for how the trucks are classified and which trucks can be used in which environments to prevent fire or explosion. Fuel handling and storage, battery charging and lighting are also covered.  

6. Overhead and Gantry Cranes (110.179)  
The section on overhead and gantry cranes “applies to overhead and gantry cranes, including semi-gantry, cantilever gantry, wall cranes, storage bridge cranes, and others having the same fundamental characteristics. These cranes are grouped because they all have trolleys and similar travel characteristics.”

To ensure that lifting equipment is safe to work with, OSHA requires all cranes be inspected and load tested by a third party.  They put a certified sticker on each crane that passes, so employees know the crane is in good condition. Each foundry should be sure to inspect not only the cranes but spreader bars, chains, cables, hooks, and custom-made lifting devices. Most engineering firms that certify custom-made devices will only certify your prototype after they have reconstructed it to ensure the base materials are strong enough and welds will hold for the load weight certified.

7. Abrasive Wheel Machinery (1910.215)  
This section has guidance on guard design, flanges, work rests, and many types of guards.

OSHA notes the work rests for hand held and pedestal grinders “shall be used to support the work. They shall be of rigid construction and designed to be adjustable to compensate for wheel wear. Work rests shall be kept adjusted closely to the wheel with a maximum opening of one-eighth inch to prevent the work from being jammed between the wheel and the rest, which may cause wheel breakage. The work rest shall be securely clamped after each adjustment.”  

Wheels should be checked and adjusted at least once at the start of the shift and more often if conducting heavy grinding.  The adjustment should never be made with the wheel in motion.

8. Bloodborne Pathogens (1910.1030)
This section cautions employees to not touch or allow exposure to potentially infectious materials such as blood, vomit, and saliva. If a facility is not within four minutes of a medical facility, it must have some staff trained to provide First Aid.  Any employee whose job duties provide potential exposure to infectious waste must be trained to understand the risks and the diseases that can be conveyed by body fluids such as HIV and Hepatitis B Virus. Post-exposure evaluation and follow-up, communication of hazards, and recordkeeping must be provided to those employees.

The plan must be reviewed and updated at least annually and whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure.

9. Hazard Communication (1910.1200)  
OSHA says the “purpose of this section is to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees.”

The purpose of the standard is to ensure all containers are labeled with their contents and that employees have access to Safety Data Sheets (SDS) and receive training to understand the hazards of working with various chemical products and how to protect their health. The United States has joined the Globally Harmonized System (GHS) which is used world-wide. It includes pictrograms in red diamonds that represent the hazards and 16 sections of information including the ingredients, the hazard classification, personal protective equipment (PPE) required, symptoms of exposure, and other relevant information. Each company must develop a written hazard communication program to transfer this information to employees. All employees must have ready access to the SDS and are free to take copies for their own use or to take to their doctor.  

10. OSHA General Duty Clause (1910)
Section 5(a)(1) of the OSHA Act of 1970 requires employers to provide their employees “with a place of employment that is free from recognized hazards that are causing or are likely to cause death or serious harm.”

Some examples of OSHA citations under the clause include:
Prevention of heat exhaustion, heat stroke, and hypothermia.
Protection from extreme weather events.
Workplace violence.
Repetitive motion injuries.
Combustible dust.
Warehouse racking.

Schorn also has advice for foundries on how to include ergonomics. They include reducing the number of steps a person has to carry an item, ensuring workers don’t have to twist while carrying loads, and addressing table heights.

“Some of those things aren’t high-tech. They don’t require automation,” Schorn said. “They simply require some kind of a job hazard analysis. Those are things you can learn how to do online. You can look up standards for ergonomics in a lot of places without a lot of trouble.”    

Click here to see this story as it appears in the April 2018 issue of Modern Casting