Safety Stand-Down Day: Confined Spaces/Machine Guarding

Confined spaces and unguarded machines present significant safety challenges for scrap facilities across the country, with machine guarding representing the 9th most cited OSHA violation last year. As you plan your safety outreach and training, consider using the safety training workbook and other safety resources below.

From the Field, Joe Bateman

As a result of some large OSHA fines in our industry lately, safety professionals everywhere are rethinking what we have always believed about Confined Spaces. What once were accepted as Non-Permit-Required Confined Spaces are now being re-evaluated as to whether they should be Permit-Required.

One element of a Permit-Required Confined Space is “converging walls” that could make it difficult or impossible for a person inside that confined space to get out. Recyclers have been cited in the past year under this definition with regard to horizontal balers with feed hoppers that have converging walls. Consider: Does the hopper of your baler have converging, or funnel-shaped, walls? If so, OSHA looks at that baler as a Permit-Required Confined Space.

OSHA fines over $100,000 have resulted in some of these situations. Don’t let it happen to you. Take a close, careful, honest look around your operation and make sure you’re compliant. If you have questions, call ISRI Safety and let’s talk it through. We’re here for you if you need an onsite safety program assessment. This service is one of your member benefits, and the only thing we ask is the investment of your time.

One of the most critical issues with confined spaces is rescue. So—if I hit my head, or go into a diabetic coma while I'm in your confined space—do you have a way to get me out of there without pulling off my arms and legs and head? Are you sure? Have you practiced? Don’t wait until an emergency happens to know whether you can respond effectively.

Finally, if you have signs on your balers, shredders, pits, or anywhere else out in your operation that say “Confined Space: Enter by Permit Only” you better have a file somewhere full of completed confined space permits. Take this time now to assure your Confined Space Program is everything it should be.

From the Field, Commodor Hall

Employee exposure to unguarded or inadequately guarded machines is prevalent in many workplaces. Consequently, workers who operate and maintain machinery suffer approximately 18,000 serious injuries, and over 800 deaths per year. Amputation is one of the most severe and crippling types of injuries in the occupational workplace, and often results in permanent disability. In addition to serious injuries and deaths, machine guarding was the 9th most cited OSHA violation for 2014.

Moving machine parts have the potential to cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. Safeguards are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact injure the operator or others in the vicinity, the hazards must be eliminated or controlled.

As part of the ISRI Safety Stand-down Initiative, these safety resources are being provided to ISRI members. Please share this information with your frontline employees and managers, and be sure to provide us with feedback.

Value of Certification
A health and safety management system is a key piece of improving a facility’s safety culture. Beyond the comprehensive analysis of existing risks and hazards, the system makes written procedures, training protocols, and continual improvement part of the everyday culture among your staff. Talking about lockout tagout, confined space, and mobile equipment safety is important, ensuring that it is done properly every single time is what keeps your people safe.
For more information about implementing a management system visit

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