Editor's Note: This is the third in a series of articles about ANSI safety standards and solid waste equipment.
Any Discussion of baler safety must begin by noting how useful these machines are — and how dangerous.
Balers have always been useful and are becoming more so as technology advances. Over the past decade, Cincinnati-based Rumpke Consolidated Cos. has replaced a network of small local recycling facilities with fewer large regional facilities. Improving baler technology has made that possible. “Today, you can locate a recycling plant every 120 miles, instead of every 60 miles, because you can put more product through a material recovery facility (MRF) and process it faster,” says Jerry Peters, corporate Occupational Safety and Health Administration (OSHA) compliance manager with Rumpke.
Balers are one of the key factors limiting throughput at recycling plants. “We couldn't have built these facilities without high-capacity, highly productive balers,” Peters says. “In one facility, we needed balers that could handle 30 tons per hour of corrugated cardboard and 40-plus tons per hour of newspaper. Today, these machines are available.”
Of course, balers also pose tremendous risks to life and limb. And the larger the baler, the greater the potential risk. Safety measures developed by OSHA combined with voluntary standards developed by the solid waste industry working through the American National Standards Institute (ANSI) are helping to reduce injuries and fatalities caused by baler accidents.
Even so, research by the National Institute for Occupational Safety and Health (NIOSH) found that 43 people died in baler accidents between 1986 and 2002. That's between two and three people per year — too many if you are an OSHA official, baler manufacturer or a waste management company.
Safety professionals say that there is no secret to reducing baler-related fatalities and injuries. OSHA officials, standards developers, and industry executives must continue to search for ways to manufacture safer balers, implement safe operating procedures, applying those lessons learned from accidents. They must then turn this information into regulations in the case of OSHA and standards in the case of organizations like ANSI. Finally, they must train and retrain everyone who works near a baler in relevant safety procedures.
“The basic idea behind safety standards is to keep people, fingers, legs, arms and other body parts out of a baler chamber,” says Gary Fleming, director of engineering with JV Manufacturing Inc. in Springdale, Ark. “Education and training in the function and operation of the equipment is important to this. If users understand how the equipment works, they will better understand how to operate it safely.”
Failures Of Communication
Today, many, if not most, baler accidents appear to be either failures of communication by safety managers or errors in judgment by operators. One executive of a baler manufacturing company recalls investigating an accident that involved a horizontal baler in a MRF. A laborer had walked up the conveyor feeding a large baler to loosen a jam. He succeeded but lost his footing and plunged into the chamber. The ram activated, cutting off both of his legs. Only the quick response of co-workers saved his life.
Later, during the accident investigation, the worker claimed that the machine had been shut down in accordance with safety regulations but had somehow started by itself. The baler executive produced the manual and showed investigators the pages describing lockout/tagout procedures, acceptable methods of entering the confined space of the baler chamber and other safety procedures supported by the design of the baler.
He conducted a demonstration proving that a machine that has been properly shut down requires a slow and deliberate re-start process. The operator must stand at the control panel, far from the hopper and the chamber, while pressing and then holding the start button for 20 seconds. When the button is pressed, an audible alarm sounds. Still, the ram will not operate for 20 seconds. If, during those 20 seconds, the operator releases the button, the machine would not start up.
Confronted with a demonstration that the machine worked the way the manual said it should work, the worker admitted that he had not shut down the machine. Instead, he said he had felt sure the machine was off because he had not heard the motor running.
“I shudder to think about the number of times this kind of thing happens,” says the executive from the baler company. “Owner/operators must make sure that everyone — everyone — in a plant [understands] how to shut down these machines. Where is the emergency shut down control for all of the equipment? How do you shut down and lockout a baler before entering the chamber? We provide training when the machines are installed. We often don't get everyone in the facility, but we get everyone we can. In the end, it is an owner's responsibility to make sure that everyone gets trained. Owners should also keep records of the training.”
What caused the accident that cut off the worker's legs? A failure by the safety department to train and retrain adequately? An error in judgment by the operator? Or, some deficiency in the machine's safety design?
Whatever the cause, every baler accident should and usually does lead to a thorough review of each of those areas. Eventually, the important lessons learned from those investigations filter into OSHA regulations and ANSI standards. The standards concerning baler safety are developed by a subcommittee of the ANSI Accredited Standards Committee Z245, which is administered by the Waste Equipment Technology Association (WASTEC).
Making Safer Balers
At least every five years, the ANSI subcommittee that deals with balers issues a revised ANSI standard. The most recent standard, which came out in 2004, introduced several important changes.
Historically, the baler standard covered manufacturers' responsibilities for designing and making safe machines as well as the responsibilities of owners for training installers, operators, maintenance personnel and others working in the vicinity of a baler. In 2004, the baler subcommittee broke the standard into two pieces: A245.51-2004 for manufacturers and Z245.5-2004 for installers, maintenance technicians and operators.
“In addition, we added more than 30 pages to the manufacturing standard to cover electrical safety standards developed by Underwriters Laboratories (UL),” says Jim Cunningham, director of engineering with Marathon Equipment Co. in Vernon, Ala., and the chairman of the ANSI subcommittee on balers.
Cunningham cautions that a UL certification related to industrial equipment covers electrical safety but nothing else. “It doesn't cover things like safety interlocks, guards, warning decals and other issues unrelated to electricity,” he says.
While 2004 was a year of change for the baler ANSI standards, great challenges involving international standards may arise in the future. According to Cunningham, manufacturers selling products in the European Union (EU), for example, must meet the requirements for the CE Marking to certify that the product's design conforms to applicable EU standards. The term “CE” has been used for so long in Europe that no one remembers what the letters stand for. According to Wikipedia, CE may have originally referred to Communaute Europeenne or Conformite Europeenne, both of which are French expressions meaning European Conformity.
Similarly, companies selling in Canada must meet the requirements of provincial safety reviews (PSRs), which parallel the standards referred to by the CE Marking. “These standards are more vigorous than ANSI standards,” Cunningham says.
For example, the PSR and CE conventions require machinery to meet safety standards in one of four categories of risk, with Category One being the lowest standard and Category Four being the most stringent. Balers built to current ANSI standards do not meet Category One requirements, while Canadian safety inspectors want balers to satisfy the Category Three standard.
“That is a wide disparity,” Cunningham says. “What if a U.S. company ships a Category One machine to Canada, and there is an accident? Does that open the U.S. company to liability? In the future, I see U.S. customers requiring that U.S. manufacturers meet these more strict international standards.”
What does the baler user standard, ANSI Z245.5, mean to a waste management company? “While OSHA regulations cover workplace safety, they tend to be general,” Peters of Rumpke says. “ANSI standards explain what those regulations mean in terms of specific kinds of machines — balers in this case.”
OSHA regulations and ANSI standards also tend to incorporate each other. For instance, the second page of ANSI Z245.5 literally, as part of the standard, adopts OSHA 29 CFR Part 1910.146, which requires permits for anyone authorized to work in confined spaces.
Likewise, OSHA regulations frequently incorporate ANSI standards to provide details. OSHA 1910.6, for instance, states that OSHA regulations will, from time to time, incorporate standards by referring to them. When this is done, OSHA 1910.6 states “the mandatory provisions of standards incorporated by reference are adopted as standards under the Occupational Safety and Health Act.”
“This means that OSHA will enforce the mandatory sections of ANSI standards referred to in OSHA regulations,” Peters says.
OSHA 1910.6 then fills eight pages with double columns listing ANSI and other standards that are referred to in various sets of regulations. Issued in July of 2004, the latest version of OSHA 1910.6 does not mention ANSI Z245.5 or Z245.51, because that standard had not been issued when 1910.6 was written. “Even so, when OSHA is on our site, they look at the ANSI Z245 series of standards which cover the waste industry,” Peters says.
The interplay between OSHA regulations and ANSI standards helps make OSHA regulations clear, Peters adds. OSHA regulations, for example, list three characteristics of a confined space: a space that has limited or restricted means of entry or exit, is large enough for an employee to enter and perform assigned work, and is not designed for continuous occupancy by the employee.
What does that mean in the case of a baler? Is a baler compression chamber a confined space? There are a couple of ways to get into a baler chamber — through the chute and through the chamber door. Does that satisfy OSHA's restricted means of entry requirement for confined spaces?
The ANSI Z245.5 standard leaves no room for doubt, defining a confined space as “an area within the baler that has adequate size or configuration for personnel entry, has limited means of access or egress, and is not designed for continuous employee occupancy.”
When necessary, definitions in ANSI standards fill in details related to the more general definitions found in OSHA regulations.
Matters of Judgment
“When we install a baler, we demonstrate all of the relevant safety procedures,” says Ed Correale, chief engineer with PTR Baler & Compactor Co. in Philadelphia. “We leave a video, a manual and all of the documentation behind with the customer. But when we leave, it is the responsibility of the customer to make sure that employees stay up to date — as old employees need refresher training and as new employees arrive.”
OSHA regulations filled out by the ANSI baler standard help Peters develop several appropriate training programs for Rumpke employees. First, there is a general baler operator course. Then, there are specific programs, such as those that train authorized employees in lockout/tagout procedures that precede maintenance. Next comes training for maintenance personnel related to working in confined spaces.
Once again, OSHA regulations require each of these training programs, and ANSI Z245.5 to help safety managers comply with OSHA by providing details that flesh out OSHA generalities. Under OSHA, for instance, there are two types of employees: affected and authorized. In the world of balers, an authorized employee has been trained to lockout and tagout a baler. An affected employee is someone that must stand by until the lockout/tagout procedure has been completed.
OSHA 1910.146 defines permit-required confined spaces, and ANSI Z245.5 explains what that means to baler operators and maintenance mechanics. “You must have an authorized, written permit before you can do any work around a confined space,” Peters says. “And, you cannot get a permit until you have been trained and qualified in lockout/tagout procedures. When you have completed that training, your supervisor will give you a permit.”
If a machine that is baling cardboard jams, an authorized employee must lockout and tagout the baler to loosen the jam. Affected employees must wait until the lockout/tagout procedure has been completed. Everyone that goes into the machine to work on a jam or to perform any other maintenance work must be trained in lockout/tagout, must have a permit and must apply his or her own lock to special locking devices.
Again, there are no mysteries to baler safety. It is a matter of sound design and sound procedures for working around, operating and maintaining the products. The work procedures are time consuming, and sometimes the design enhancements are expensive, but they will not surpass the cost of workers' compensation bills safety professionals say. Frequently, employees think it would be easier and more efficient to reach into the chamber and loosen a jam, rather than taking the time to go through a lockout/tagout procedure. In the end, it is those errors that cause the bulk of baler accidents, but it is sound judgment that the best training programs aim to develop.
Gary Satterfield is executive vice president of the Waste Equipment Technology Association. Michael Fickes is a Westminster, Md.-based contributing writer.