Punch Press Lockout/ Tagout requirements
Punch Press Lockout/ Tagout requirements
(OP)
We are a large manufacturer that uses literally hundreds of mechanical punch presses. They are 12 ton, foot pedal triggered models for the most part. We have a very detailed lockout tagout program complete with specific lockout procedures posted on each machine. There has been some debate on whether or not the machine should be locked out when a die is not in it. It is understood that lockout is required when removing or loading a die but the question is; should it be locked out when sitting empty. Any thoughts, ideas, sources?





RE: Punch Press Lockout/ Tagout requirements
If there is a question about leaving equipment isolated for long periods, such as some one has inadvertantly defeated isolation. The procedure must be, before starting work confirm isolation is still in place.
Does your isolation procedure include insertion of a chock under the platten?
Mark Hutton
RE: Punch Press Lockout/ Tagout requirements
RE: Punch Press Lockout/ Tagout requirements
I'm not familiar with the 'basic rules' you refer to - surely your plant has a management process for tagouts? It seems unduly restrictive that the only person who can remove a tagout is the person placing it!
The key aspects must be that the isolated eqpt is inoperable / de-energised, the tag should have a reference as to when and WHY it was placed. As long as the operator procedures for use of the machine account for the sensible removal of tags i.e. once machine is established as fit for use (i.e. not under maintenance, withdrawn from service or linked with other upstream or downstream maintenance) and the operator has put in the next die according to their training / procedural checks then why shouldn't a different operator remove a tagout?
I have to say i agree with HEC - what is the problem leaving a machine tagged out? Apart from your 'rule' re tag removal it seems eminently sensible.
Question - what would your company do if the person who had placed a tag on (say) 100 machines suddenly got hit by a bus? Decide what you would do to untag the machines and then just make that part of your general management / operating processes.
Kind regards, HM
No more things should be presumed to exist than are absolutely necessary - William of Occam
RE: Punch Press Lockout/ Tagout requirements
RE: Punch Press Lockout/ Tagout requirements
RE Sources, you could try the following which are UK based codes of practice but you could look at the general principles.
http://www.hse.gov.uk/pubns/priced/hsg253.pdf is the "good practice" for process plant isolations but the ideas should be similar to what you want
you could also look at http://www.hse.gov.uk/pubns/priced/hsg250.pdf which is the guidance for permit to work systems
Regards, HM
No more things should be presumed to exist than are absolutely necessary - William of Occam
RE: Punch Press Lockout/ Tagout requirements
On a side note, I would be very concerned about your initial statement about your punch presses being foot activated. Do you have some other form of guarding to prevent operators from putting their hands into the point of operation? OSHA is very specific in their operation requirements for mechanical power presses(including punch presses). Also, OSHA is in the early stages of developing new regulations for all presses so be aware of future changes.
RE: Punch Press Lockout/ Tagout requirements
As to the side note. We have machinists dedicated solely to guarding 40+ hours per week. The guards on our dies are specifically designed to admit the material only (profile cut-outs). No room left for body parts. In addition to that, all pedals are fitted with the correct cover to prevent accidental trip. Some of the materials that we punch are quite large so two hand trip mechanisms aren't practical without radical workstation design changes. The operations that can be converted to a two hand trip or similar controls have been. We very recently completed an OSHA inspection (still waiting the report in fact) so we'll get it first hand very soon if we aren't compliant in that area. From the inspectors' at the time of the audit, the guarding was more than sufficient.
RE: Punch Press Lockout/ Tagout requirements
Mark Hutton
RE: Punch Press Lockout/ Tagout requirements
The OSHA regulation 1910.147(c)(5)(ii) states "Lockout devices and tagout devices shall be singularly identified; shall be the only devices(s) used for controlling energy; shall not be used for other purposes"
What this means is that you may only use a company supplied lock for locking out a machine. Conversely this lock may only be used for locking out a machine and not for anything else, as it states at the end of that rule. Since the machine is not techinically being locked out for the machine to be worked on, you may not use a lock out lock on it.
Here is an OSHA letter of interpretation about this subject. ht
Hope this helps.
RE: Punch Press Lockout/ Tagout requirements
This is exactly what I was looking for. I believe some international rules may differ from OSHA on some of the finer points of this subject. I looked for quite a while for a letter of interpretation on the subject and could not find one. We did make the rule, incidentally, that LOTO is not to be used for a machine that is simply sitting unused or unloaded unless that condition creates a specific hazard. It was determined in-house that an unloaded punch press creates less hazard than a loaded press (which is not locked out when not in use) so they are simply left turned off.