Published by:

Peterson Publications, Inc.

2150 SW Westport Dr., Suite 101

Topeka, KS 66614

(785) 271-5801

Fax: (785) 271-6404

The main issues to address when approaching safety in the bindery are the same as with most other areas regarding safety compliance efforts. This includes performing a hazard assessment, reviewing equipment, establishing standard operating procedures, conducting employee training, and performing regular safety inspections.

Performing a hazard assessment allows an employer to identify existing risks and/or hazards, prioritize corrective actions, and eliminate risks and/or hazards.

The basics of performing a hazard assessment involve conducting a full examination of work practices and production operations such as material handling, equipment operations, and personal protective equipment (PPE). From this examination, the necessary information will be gathered to break down the process to the point where risks and/or hazards can be isolated and identified. The final step in the process is the development of a system for understanding the possible consequences of the identified risks and/or hazards and establishing any corrective measures.

The important principles of an assessment include eliminating risks (and more importantly, addressing risks at the source), adapting work to the individual (if possible), and utilizing technology (when available/practical). Then it is important to implement measures plant-wide, including employee training and involvement. Finally, develop an assessment review schedule to ensure that continued safety is maintained.

Some of the more task-specific hazard assessment efforts involve investigating reported risks or hazards by employees, addressing “close-calls” which can quickly lead to an accident or injury, and introducing a safety review for all newly created jobs and/or jobs with any procedural or process changes.

In any production environment where equipment is used, special attention will need to be provided on equipment operations. The three basic areas to address with regard to equipment are service and maintenance, minor service and maintenance, and guarding.

It is vital that all machines and pieces of equipment be maintained and serviced regularly. This activity will ensure not only that the equipment is operating efficiently, but that its safety features are intact and providing the highest level of protection for the employees. When performing any service and maintenance activities, the use of lockout/tagout procedures is required in order to prevent any unexpected activation or release of stored energy while an employee is working on the equipment.

Accidents as a result of not applying proper lockout/tagout procedures in the bindery and finishing department can have severe consequences. In one recent example, an operator working on a three-knife trimmer had his fingers severed when he was making adjustments and did not follow the proper lockout/tagout procedures. The operator shut off the machine, yet while he had his hands inside the unit clearing the jam, another employee accidentally engaged the equipment and caused the knives to motion, resulting in the amputation. Had the employee followed the proper lockout/tagout procedures, the injury would not have occurred.

The lockout/tagout standard requires the adoption and implementation of practices and procedures to shut down equipment, isolate it from its energy source(s), and prevent the release of potentially hazardous energy while maintenance and servicing activities are being performed. It contains minimum performance requirements and definitive criteria for establishing an effective program for the control of hazardous energy.

There is an exception to the lockout/tagout standard, known as “minor servicing and maintenance”. In order for the exception to apply, the employer must ensure that the employee can effectively perform the minor service and maintenance task in a way that prevents exposure to a hazard, such as by the use of special tools and/or alternative procedures which keep the employee’s body out of the areas of potential contact with machine components or which otherwise maintain effective protection.

“Minor servicing and maintenance” is defined by OSHA as “those tasks involving operations which can be safely accomplished by employees and where extensive disassembly of equipment is not required” and the task must be considered routine, repetitive, and integral to the operation. 

Under “minor servicing and maintenance”, lockout/tagout procedures are not required if the employer can demonstrate that the alternative protection measures enable the employee to perform the servicing and maintenance without being exposed to unexpected energization, activation of the equipment, or release of stored energy.

It needs to be understood that this exception does NOT exempt printers from establishing a lockout/tagout program. Printers still need to establish a compliance program for major servicing activities, e.g. electrical repairs, removing major components, etc. More information can be obtained on lockout/tagout requirements at www.gain.net.

While service and maintenance and minor service and maintenance are necessary for non-production activities, guarding is the rule for all production activities. Any machine part, function, or process which may cause injury must be safeguarded while the equipment is in the production mode. Such guarding includes fixed type, adjustable type, and interlocked.

It is important to note that OSHA does not allow the grandfathering of equipment with regard to guarding issues. So no matter the age or design of the equipment, proper guarding must be in place for production activities and must offer the required level of protection from obvious or potential hazards.

Standard Operating Procedures

The use of standard operating procedures (SOP) is an essential safety tool when specific details are needed beyond that of a general written program, or in cases where a formal written program is not required but for safety reasons a specific set of procedures is necessary in order to properly perform a task or job function. The most common SOP’s for the bindery department are developed for material handling activities and specific equipment operation. 

Material handling can involve moving materials either by mechanical means or by physical efforts. Both means should have SOP’s in order to reduce or eliminate any hazards or potential hazards. The SOP’s in this category would include instruction on such subjects as how to properly lift, load, and unload materials, and when and how to use mechanical means, as in forklifts and pallet trucks.

Specific equipment operations require specific sets of instructions. A great source for developing the instructions is the manufacturers’ operating handbook. Whether it is for a folder, a guillotine cutter, or forklift truck, using and/or incorporating the operation handbook as an instructional guide will assist in properly training the employee. Details should be provided so employees will understand under what conditions they are allowed to operate equipment, the intended design for the equipment, and any associated hazards while using the equipment. In some cases, a printer may find that a unique application or job requirement calls for a variation of the normal operating procedures. In such cases, a new hazard assessment needs to be performed and new operation procedures established that will allow for the operation while still providing an adequate level of employee protection.

In some situations, a written safety program can serve as an SOP, depending on how it is written. Written programs are the documents that help guide employees in the understanding and application of certain OSHA regulation requirements. They may outline how compliance will be achieved but may not provide the employee with enough equipment-specific or task-specific instruction. Most written safety programs are designed to reflect only the compliance aspect of an OSHA regulation and some formats lack the detail needed to use as an effective procedural guide. It’s also worth noting that not every production task has an associated written program requirement from OSHA, which makes SOP’s all that more important.

Employee Training

After the equipment is outfitted for safety devices and features, after the warning signs are in place, and once the policies and procedures are written, the key to safety on the job is put in place – the employee. Without a proper understanding of what is expected, how to perform tasks safely, how to use equipment safely, or how to recognize hazards, the human element will be a wild card for the employer.

Conducting safety training is the responsibility of the employer. Understanding and following the safety rules and procedures is the responsibility of both employer and employee. It is always in the best interest of the employer, as well as the employee, to see that safety training is conducted and periodically updated even beyond the requirements of OSHA. Understanding that mistakes do happen, in most cases accidents and injuries can be categorized as resulting from unsafe actions and/or unsafe conditions. Both of these situations can be avoided through proper safety training.

Employers must not only determine that their employees can technically perform their work assignments, but that they can perform them safely and in accordance with the requirements of company safety polices and OSHA regulations.

Safety training and work task procedures should go hand in hand. Being properly trained is to be trained in the best methods for completing the job tasks, while also maintaining the highest level of personal safety. The training curriculum should identify who should be trained (e.g. new and/or existing employees), the type of training that is required (e.g. initial, remedial, refresher), when the training should occur, and the frequency of the training.

Because it is not always possible for employers to monitor every aspect of an employee’s work day, it is crucial that the safety training provides enough understanding and information to allow the employee to sustain the necessary level of safety awareness and carry out work assignments in the safest manner. 

Inspections

As a good rule of thumb for effective safety management, a general safety inspection should be incorporated as part of a regular business review and should be conducted every six months, but not less than annually. 

These inspections must periodically be made in order to ensure that the rules and policies are still accurate, being enforced, and that all necessary control measures, if any, are being implemented. Inspections also serve to demonstrate the company’s commitment to safety.

Regular inspections should cover a check of the equipment to verify safety devices such as interlocks and guarding, as well as the proper operation of the equipment itself. A review of the safety records should also take place, which would include the OSHA Injury and Illness 300 log, employee training records, written safety programs, and SOP’s. Some individual OSHA regulations, such as lockout/tagout, will actually mandate that procedures and authorized employees be evaluated at least annually. A list of such mandatory inspection and review events, as well as voluntary inspections, should be developed and scheduled.

A physical walk-through of the area during production with an eye to safety is a good way to observe work area conditions and employee activity live. Generally, the bindery is the last stop before a product is warehoused or shipped to a customer. This is where a vast amount of material can be stored, stacked, and moved about between several finishing stations before ultimately moved out. Depending on the materials being handled, there can be hand trucks and forklifts used, as well as scrap material that is cut or trimmed off finished product, all contributing to slipping, tripping, and crushing hazards.

Always observe your operation, be aware of your employee’s performance, investigate problems, listen to suggestions, and immediately address any needs for safety training.