June 1, 2011
Protect employees from moving machine parts.
By Therese Dunphy, Editor-in-Chief
When it comes to protecting miners from moving machine parts, the Mine Safety and Health Administration (MSHA) recommends three types of strategies for guarding. They include the following:
• Guarding at the point of contact.
• Guarding by locating moving machine parts out of normal reach.
• Enclosing multiple moving parts in a single guard or preventing access to moving parts in a specific area.
Often, however, the issue is not what to guard, but how to guard. “If you’ve got potential employee exposure at the ground level, you want to make sure you have adequate guarding in place,” says Nancy Moorhouse, corporate safety director of Sacramento, Calif.-based Teichert Aggregates. “While mine sites have guarding in place, part of the challenge going forward is to understand what the definition of adequate guarding is according to MSHA.”
Clearly, not all operators — or possibly even inspectors — have a clear understanding of what constitutes an adequate guard. From 2005 to midway through 2010, MSHA inspectors issued 35,653 citations regarding moving machine parts (30 CFR 56/57.14107) making it the most common citation in metal/non-metal mines. Of those citations, 11,687 were categorized as S&S violations.
For 2010, a total of 5,403 guarding citations (30 CFR 56.14107) were issued to surface stone mines and surface sand & gravel mines. It was the most frequently issued citation in each category.
“Industry is looking for a prescriptive standard. MSHA has not offered that,” Moorhouse says. “I can see both sides of the issue; however, the mine site is a continuing work-in-progress.”
To help clarify its expectations, MSHA has followed up its 2004 Guide to Equipment Guarding (www.msha.gov/s&hinfo/equipguarding2004.pdf) with a companion training module, Guarding Conveyor Belts at Metal & Non-metal Mines (www.msha.gov/Accident_Prevention/EquipmentGuardingConveyorBelts2010.pdf), to offer supplemental regulatory guidance. The newer guide, which was released last summer, contains numerous images of guards that do and do not meet the agency’s expectations.
One area that has been clarified is the size of openings on screening materials used for guarding. While operations may have used guarding materials with larger openings in the past, it is clear that smaller screening is needed to prevent miners from sticking fingers and toes or small hand tools through the guarding materials.
When in doubt, operators should guard the equipment. “It’s getting back to doing a site assessment of where employees are relative to machine parts and what needs to be guarded to protect these employees. Start from the ground up,” Moorhouse says. “If your gut is talking to you, some additional precautions probably need to be taken.”
She suggests turning to trade associations, other safety professionals, and the mine workers themselves for guidance on areas of concern.
Moorhouse also stresses the importance of safety during maintenance activities when guards are down. She suggests taking additional precautions such as cordoning off the work area with caution tape and clearly communicating the hazards to miners. “We’ve used a communication system through pre-task planning and job hazard analysis so those who are working in the area understand that maintenance activities are going on and know the hazards that go along with it,” Moorhouse explains. Lock out-tag out and — where appropriate — block out should also precede maintenance tasks. “It gets down to a team environment where communication becomes critical,” she adds.
The Small Mine Office developed a series of weekly ToolBox talks that can be used by small mine operators and others to hold safety and health discussions for their employees at their mining operations. These ToolBox talks were developed in consultation with members of the mining community. To get the free app, enter http://gettag.mobi into your browser.