OSHA 1910.217 (C)(3)(iii) Presence Sensing Device
(iii) A presence sensing point of operation device shall protect the operator as provided in paragraph (c)(3)(i)(a) of this section, and shall be interlocked into the control circuit to prevent or stop slide motion if the operation’s hand or other part of his body is within the sensing field of the device during the downstroke of the press slide. PMA Interpretation: (c)(3)(i)(a) Refers to the functional requirement of a presence sensing device which prevents and/or stops normal stroking of the press.
(a) The device may not be used on machines using full revolution clutches.
(b) The device may not be used as a tripping means to initiate slide motion except when used in total conformance with paragraph (h) of this section. PMA Interpretation: (Note: paragraph (h) refers to very specialized and specific requirements for Presence Sensing Device Initiation.)
(c) The device shall not be constructed so that a failure within the system does not prevent the normal stopping action from being applied to the press when required, but does prevent the initiation of a successive stroke until the failure is corrected. The failure shall be indicated by the system. PMA Interpretation: When failure occurs the best indication is the press won’t run.
(d) Muting (bypassing of the protective function) of such device, during the upstroke of the press slide, is permitted for the purpose of parts ejection, circuit checking, and feeding. PMA Interpretation: Top of stroke is the point at which muting shall cease as it is not possible to set a point on the downstroke as the exact position where the hazard of die closing starts.
(f) Guards shall be used to protect all areas of entry to the point of operation not protected by the presence sensing device. PMA Interpretation: (3)(iii)(f) Great care must be taken to assure that no access to the die area exists unguarded.
OSHA 1910.217 (c)(3)(5) Additional Requirements for Safeguarding
Where the operator feeds or removes parts by placing one or both hands in the point of operation, and a two hand control, presence sensing device of Type B gate or movable barrier (on a part revolution clutch) is used for safeguarding.
PMA Interpretation: This paragraph tells the condition under which a brake monitoring system is required after November 1, 1975.
(i) the employer shall use a control system and a brake monitor which comply with paragraphs (b) (13) and (14) of this section. This requirement shall be complied with by November 1, 1975. PMA Interpretation: (b)(13) Control reliability. (b)(14) Construction requirements. (ii) the exception in paragraph (b)(7)(v)(d) of this section for two hand controls manufactured and installed before August 31, 1971, is not applicable under this paragraph (c)(5);
PMA Interpretation:
When brake monitoring is required, two-hand controls manufactured and installed before August 31, 1975, must be designed to require release of all operator’s hand controls before an interrupted stroke can be resumed.
(iii) the control of air clutch machines shall be designed to prevent a significant increase in the normal stopping time due to a failure within the operating valve mechanism, and to inhibit further operation if such failure does occur, where a part revolution clutch is employed. The exception is paragraph (b)(7)(xi) of this section for controls manufactured and installed before August 31, 1971, is not applicable under this paragraph (c)(5).
PMA Interpretation: When a brake monitor is required this paragraph removes the exception on valve mechanism manufactured or installed before August 31, 1971. All machines regardless of age used for hands-in-the-die-feeding or unloading and using a two hand control device, presence sensing device or type B gate must utilize a dual self-checking air valve.
OSHA 1910.217(e) Inspection, Maintenance, and Modification of Presses
(1) Inspection and maintenance records.
(i) It shall be the responsibility of the employer to establish and follow a program of periodic and regular inspections of his power presses to insure that all their parts, auxiliary equipment, and safeguardings are in a safe operating condition and adjustment. The employer shall maintain records of these inspections which includes the date of inspection, the signature of the person who performed the inspection, and the serial number, or other identifier of the power press that was inspected. PMA Interpretation: Records of clutch and brake will be weekly. Other inspections are periodic subject to time factor determined by employer.
(ii) Each press shall be inspected and tested no less than weekly to determine the condition of the clutch/brake mechanism, antirepeat feature and single stroke mechanism. Necessary maintenance or repair or both shall be performed and completed before the press is operated. The employer shall maintain records of these inspections and the maintenance work performed. These requirements do not apply to those presses which comply with paragraphs (b)(13) and (14) of this section. The employer shall maintain a certification record of inspections, test, and maintenance work which includes the date of inspection, the signature of the person who performed the inspection, test or maintenance; and the serial number or other identifier of the press that was inspected, tested or maintained.
PMA Interpretation: If brake monitoring system is installed, weekly inspection and records are not required for clutch/brake mechanism. Other parts of the press will require periodic inspections and records.
(2) Modification. It shall be the responsibility of any person modifying a power press to furnish instructions with the modification to establish new or changed guidelines for use and care of the power press so modified.
(3) Training of maintenance personnel. It shall be the responsibility of the employer to insure the original and continuing competence of personnel caring for, inspecting , and maintaining power presses.
PMA Interpretation: PMA’s’s training material will assist you in meeting this requirement.
OSHA 1910.217(5)(c) Operation of Power Presses
(2) Instructions to operators. The employer shall train and instruct the operator in the safe method of work before starting work on any operation covered by this section. The employer shall insure by adequate supervision that correct operating procedures are being followed. PMA Interpretation: PMA’s new training manual for press operators will help you meet this requirement.
(3) Work area. The employer shall provide clearance between machines so that movement of one operator will not interfere with the work of another. Ample room for cleaning machines, handling material, work pieces, and scrap shall also be provided. All surrounding floors shall be kept in good condition and free from obstructions, grease, oil, and water.
PMA Interpretation: Good general housekeeping is always required.
(4) Overloading. The employer shall operate his presses within the tonnage and attachment weight ratings specified by the manufacturer.
PMA Interpretation: Check tonnage and weight of die at time of diesetting.
