May/June 2018
By Rachel H. Pollack
Anyone who’s lived with a toddler will recognize the concepts of hazard assessment and machine guarding. You go through the house room by room and install physical barriers—electrical outlet covers, cabinet locks, gates in front of stairs—to ensure the child doesn’t accidentally come to harm. In a scrapyard, machine guarding is like “baby-proofing for adults,” says Bill Rouse, quality, environment, health, and safety manager of PK Metals (Coram, N.Y.). Without proper guards, workers risk lacerations, amputation, and even death from getting clothes or body parts caught in equipment. Machine guarding “saves our extremities and our lives,” says Lisa Dunn, director of QEH&S for Becker Iron & Metal (Venice, Ill.).
In a hazard assessment, a scrap facility’s first concern should be whether machine guards are adequate to keep workers safe. You might need to supplement existing guards with additional structures. The goal is “having guards in place that are not easily removed or bypassed,” says Rich Allee, nonferrous operations manager and EHS program manager at Rocky Mountain Recycling (Commerce City, Colo.). “If a guard is designed right and is in place, someone will have to work at getting in harm’s way.”
That’s where the mental barriers come in. When employees feel a machine guard is slowing them down or otherwise in the way, they’re likely to remove it or circumvent it, exposing themselves to the hazards the guard was blocking. “From my field experience, I’d say one in every five scrapyards has machine guarding issues,” says Hamid Abuzaid, an occupational health and safety specialist with GCG Risk Management (Schenectady, N.Y.). Education, clear policies and procedures, and sometimes serious consequences for those who don’t comply are strategies scrap facilities use to ensure guards remain used and in place.
Guarding the Alligator Shear
When scrap safety managers talk about machine guarding challenges, alligator shears—along with conveyors and grinders—are high on the list. PK Metals turned an Occupational Safety and Health Administration citation into an alligator shear guarding innovation that several other yards have since implemented successfully. About five years ago, Rouse says, while OSHA inspectors were reviewing the company’s injury and illness records, they noticed a report of a fingertip amputation that had occurred at the shear three years earlier, one of three recordable injuries that had occurred on that equipment in three years.
The inspectors made a beeline for the shear and declared the cage over the shear blade insufficient to meet the OSHA standard for shear safety. The guarding around a shear must prevent workers’ hands from reaching the blade, they pointed out, and the cage does not do so. “A lot of people make the assumption that having that [built-in] guard is enough,” Rouse says, but OSHA told him otherwise. “You must look at your own situation, your own material you’re cutting, and adapt to that.”
PK Metals’ solution was to weld a tabletop around the shear to achieve guarding by distance. (Rouse credits the idea to Lee Twitchell, safety and environmental compliance manager of Metro Group in Salt Lake City; Twitchell says Rouse deserves the credit.) The tabletop adjusts to ensure workers can’t reach the shear blade, even if they’re leaning across the table toward it. To hold small pieces of scrap for cutting, they must use an additional tool such as a pair of pliers. The operating pedals and emergency stop button move with the tabletop to be within workers’ reach. The woman who regularly operates one alligator shear to cut copper at his facility is
4 foot 8, Rouse notes, and he’s 6 foot 2. The guard adjusts to allow either of them to use the shear safely. He put the guard in place five years ago, and PK Metals has not had an alligator shear injury since, he says. It also hasn’t seen a loss in productivity in shear operations, he adds.
The cage around the alligator shear blade is still important, Rouse says, to keep cut scrap from flying out of the blade and injuring someone nearby. “It actually works better now because [operators] can keep it lower,” he says. Other safety managers say shear operators complain the cage’s bright yellow color impedes their view of the scrap as it comes in contact with the blade. One solution is to paint it flat black. It’s like “if you had a black screen in your window, you could see outside,” says David Medeiros, EH&S manager of Mid City Scrap Iron & Salvage (Westport, Mass.). “We tried that, and it made a difference on the machines where we were trying to cut small pieces.”
Training Techniques
At Rocky Mountain Recycling, machine guarding safety training focuses first on awareness: what machine guarding is, why it’s important, and what it’s supposed to look like on each piece of equipment. “Recognize it exists in a lot of different forms, shapes, and sizes,” Allee says, and “realize that it’s there” and the purpose it serves or potential hazard it’s trying to prevent. He points out that in a scrapyard, “someone can be doing four or five different tasks in one shift … in different areas of the yard.” Thus, that person won’t always have the familiarity with the guarding on any one piece of equipment that comes from using it every day.
Also, Allee says, employees need to understand that a guard isn’t always a separate piece of equipment. “Any cover is a machine guard, and it needs to be in place for your safety and the safety of people around you.” The goal, he says, is employees “getting that mindset that it’s not OK to operate a piece of equipment if that guard is not in place [or is] damaged.”
A checklist or inspection is what many facilities use to ensure machine guards are in place. Operators must inspect the equipment before they turn it on, whether at the start of a day, the start of a shift, or after a break. “The guard’s there for a reason. The machine doesn’t run unless the guard is in place. That’s what we teach,” says Tony Smith, ISRI’s safety outreach director.
Problems can crop up when employees focus on the idea that “time is of the essence, time is money,” Smith says. An employee might decide to bypass machine guards that get in the way of production “to show the company I’m valuable,” he says. “I’ll take a shortcut and hope I get noticed by a supervisor or a manager.”
New employees in particular often want to make an impression, Rouse says. When training them, he emphasizes that they’ll impress supervisors most by operating safely. If you take shortcuts in an effort to be a star producer, and “you cause a catastrophic injury or hit a bridge with your truck, that’s what you’ll be known for,” not your productivity, he tells them.
At the same time, the longer-tenured employees are the ones more likely to bypass machine guards, these managers say. New workers are more cautious, says Jim Effron, environment and safety manager at Baltimore Scrap Corp. (Baltimore), whereas with more experienced employees, “you’ve got to keep them from getting complacent.”
Allee says his experience bears out that observation. “Whenever I talk to somebody when we’ve had an incident, to find out what the root cause was, it was probably something they’ve been doing for a while. We dodged a bullet that they didn’t have an injury before. It’s something to watch out for with [long-]tenured employees,” he says.
Jason Richey, EHS manager at Totall Metal Recycling (Granite City, Ill.), says he finds a certain mindset more challenging than a specific level of experience. It’s the employee who “thinks he’s 10 feet tall and bulletproof. [He] thinks he’s not going to get hurt.” Such employees not only put themselves at risk, they “potentially create a counterculture,” he says.
With alligator shears in particular, workers complain the guarding “is a little bit restrictive. You have to work material under it, which gets frustrating,” Dunn says. The message she conveys is, take your time. “We’d rather it take you five minutes longer and you go home safely rather than pushing to get X amount of production done,” she says. “By not putting [the time pressure] on, it relieves some of the stress from the operator employee to feel they have to work quickly versus safely.”
Safety managers also emphasize that safety is more important than maximizing scrap value. “You don’t have to get every fraction of the copper you can” when cleaning pipe, for example, Allee says. “That’s not the expectation.” As Twitchell puts it, “Putting our hands at risk to squeeze out another ounce of copper is never worth the risk. Not ever. Employees have to believe that we want them to throw that little piece of dirty copper in the dirty copper box.”
ISRI received a 2018 Susan Harwood training grant from OSHA to develop machine guarding training materials that are likely to include a PowerPoint presentation, a checklist, a video, and a quiz, Smith says. A task force of ReMA members has drafted the initial materials, and Smith plans to seek feedback on them at the ReMA Safety and Environmental Council meeting in St. Louis in June.
Maintenance Concerns
If the desire for more production or more scrap value is what leads equipment operators to bypass machine guards, speed is often the issue during equipment maintenance. “I hate to pin it all on maintenance [employees], but they’re the ones that are rushed,” Rouse says. “They’re trying to get [their work] done as fast as possible, they have 10 people waiting on them, they get rushed and frustrated, and that leads to them not putting the guard on” when they finish their work.
Alternatively, the maintenance worker is troubleshooting “an ongoing maintenance problem that’s unresolved,” Allee says. “The operator is trying to do the right thing, get their job done, and they’re willing to work on a piece of equipment when the guarding is not in place” while the maintenance person evaluates it and makes adjustments. That leaves both employees at risk. In training, Allee says, “the message is, it’s not OK to put yourself at risk.”
If maintenance and cleaning around equipment require the removal of guards, employees must follow lock-out/tag-out procedures, these safety managers say. “The job that’s being performed is not complete until the guards are replaced properly,” Smith says. “That has to be part of the process.” Allee agrees. “Machine guarding goes hand-in-hand with LOTO. Having a good procedure in place, followed consistently, for LOTO—to have everything back in place before you start up—it’s got to be part of that whole process.”
“When we have to work on a baler or guillotine shear, we’ve got to be patient, lock it out every time. And when we finish the maintenance, put everything back the right way, not halfway,” Twitchell says.
Compliance and Corrective Action
Spot inspections can motivate employees to comply with lifesaving machine guarding rules, Twitchell says. “We have to trust people. We can’t hold everybody’s hand, but we, as team leaders and managers. like to do inspections often enough that they know it really matters to us that they do it the right way every time.” Effron says he conducts spot inspections whenever he visits one of the dozen other facilities for which he’s responsible in addition to his Baltimore yard. “Every time I do a safety talk, I do a walk-through” of that facility, he says. “I look for guards, make sure they’re on and proper. When I find they’re not, I call the manager on the carpet right then.”
If the violation was serious, Effron says, “I make a written report when I get back [to Baltimore], then I e-mail it to the plant manager and to the president of the company, David Simon, whom I report to.” Knowing “I’m not going to keep it to myself” when he sees a violation has been effective, he says.
Machine guarding rules are often “cardinal” safety rules, Smith says, because of the potential seriousness of the consequences. “If you bypass [cardinal] safety rules, severe injury, bloodshed, and fatalities can happen.” It’s not a question of if an injury will occur, he says, it’s when.
Penalties for cardinal safety rule violations emphasize the seriousness of the infraction. At many yards, the first incident results in the company sending the worker home for the rest of the day; a second incident can result in termination. “I would rather have somebody really mad at me for a very healthy long time than have to knock on their family’s door and tell them that their daddy or mommy is not coming home anymore,” Twitchell says. “If an employee just won’t consistently follow our safety rules, we have to be willing to give them the chance to work for someone else.”
At PK Metals, “putting other people in danger is more severe [a violation] than putting yourself in danger,” Rouse says. “If you put other people in danger, folks don’t want to work with you anymore.” Thus, circumventing a machine guard or a lock-out/tag-out incident is likely to result in termination.
Effron also says a violation that creates a life-threatening situation can result in immediate termination. “If [an employee is] going to keep doing something unsafe, you can’t keep him there. That’s on your conscience” if you did and someone were to get hurt, he says. “For his benefit and your own,” you have to let that person go.
Some yards take a different approach, however. At Totall Metal Recycling, Richey says he prefers to focus on education, not punishment, when employees violate machine guarding rules. He’ll “find out why they were working without the guard, [and] if they even knew” the guard was missing. “Did they do the inspection properly? Are they new to the machine? Were they trained properly in the first place? First and foremost, understand why” the violation happened, he says, and “continue to follow up with them and make sure they understand.
“Typically, we have not experienced repeat offenders” with this approach, he says, but even if he did, he’d emphasize education over punishment. “Typically, the first time I reeducate you, we’d talk at the piece of equipment, conduct some hands-on training, or I’d have you talk to me after [your shift]. If it happens a second time, my first step is again re-education in the more formal stance—you’d sit down and [take] the machine guarding class all over again. The third instance [you’d be] written up and get retrained and continue to progress from there. Ultimately, it comes down to the offender,” he says. “How are they responding? Are they receptive, or combative? And what is the end state? For me, it’s a well-trained, safety-conscious employee.”
Allee says he emphasizes education over punishment as well. “We don’t ever want it to get into a disciplinary situation. We want to approach somebody and create awareness that it’s not OK to operate without guarding in place.” That said, if someone trained on a piece of equipment is not following the proper procedures, the consequences could include termination, even for a first violation, he says. “We have not had to do that, but definitely we have had write-ups and suspensions for people due to safety violations.”
Machine Guarding Wish List
The machine guarding built into scrap processing equipment has improved immensely over the past decade, these safety managers say, as has the optional guarding manufacturers make available. Despite these advances, safety professionals see room for improvement. One complaint is with bolted-on guards such as those on conveyors. When you remove them for maintenance or cleaning, Smith says, “you lose the bolts and use bungee cords [instead]. Then those give way, and the guard is sitting next to the [equipment] that it’s supposed to be guarding.” Effron says he would prefer guard panels that slide open and closed. In an ideal world, the equipment wouldn’t start if the guards were not in place, he adds.
Metro Group has replaced the bolts that hold conveyor guards in place with T-handle and star-handle bolts workers can remove by hand. Twitchell also spray-paints them a bright color “so you can spot them on the floor if you drop them.” Have spare bolts on hand “just in case,” he adds. These strategies increase the chances employees will clean behind the guards and replace them when they’re finished.
On conveyors, Effron thinks an emergency-stop rope or wire that runs the length of the conveyor should be standard instead of a stop button. “Not all conveyors have stop buttons where operators are working,” he says, and “you never know where someone is.” He has installed that equipment on most of his company’s conveyors.
Putting Safety First
In addition to training, checklists, and inspections, employee empowerment can reinforce machine guarding safety. “Ensure employees have a voice to stop production at any time,” Richey says. “Employees should not accept a lack of a guard as acceptable. … Employers should get away from the production-first attitude, and employees should take a safety-first attitude because it’s their life.”
Rachel H. Pollack is editorial director of Scrap.
Machine guarding for safety requires physical barriers, but the mental barriers can be just as important. Use proper training, policies, and procedures to ensure employees use the guards you implement to improve safety.