Heidelberg Windmill OSHA Compliance

Mike,
we have had Windmills in our shop since the 50’s, up to 6 presses and never had issues. What exactly are you worried about with OSHA?

We’ve been cited for the fact that the fly wheel design of being open and it being a pinch point. (a guarding issue for OSHA) The same with our cylinder press. Additional concerns of other employees potentially walking and/or falling around the press with its moving parts is also a hazard. I have contacted Heidelberg about any guards or safety devices that might be available and have been told there are none. The regional sales rep also tells me of taking them in on trade and reselling them without any additional safety devices being installed on them. Our shop has also been around since the 50’s and have been visited by OSHA at least three times since I’ve been here the last twenty years. No citations were issued on the previous visits. There was no explanation as to why it wasn’t cited in the past other than it must have been missed. We are hoping someone has encountered this situation and can tell us if they have received any variance or been able to retrofit their equipment to OSHA’s liking. The last three months of research has resulted in nothing.

Mike, I know what covers you are talking about. Presses we have had in the past have been missing covers or never came with covers. I would recommend finding a local sheet metal company and having them come out and make covers specifically for the presses. Hopefully that helps

in my experiance, i fought back with ” the press has all guards in place that were installed at the time of manufacture.” old machines do not necessarily need to be updated to current OSHA requirements. but each OSHA inspector is they’re own person. if you jump through the first hoop for these people god help you, they will bug you till it is easier and cheaper to get rid of the press.

Eric- I agree with your sentiment, but unfortunately your statement “old machines do not necessarily need to be updated to current OSHA requirements” is technically incorrect. OSHA rules do not have a provision for “Grandfathering” older equipment. Either a piece of equipment meets the rules or it doesn’t…. no matter how old or wonderful it is. I’ve fought that rule several times, and lost every time. Several years ago, they forced the retirement of a very fine old Pantograph Router for making wood type. (I still use it for my own purposes though.)

The real problem is not with OSHA themselves. Nowadays they are rather toothless and wishy washy. The real problem is in liability if an employee gets injured while operating the machine. If a machine is not in compliance with OSHA rules, an injured employee can claim “gross negligence” and you will be liable for far more than Worker’s Comp rules dictate. Legally this is called “piercing the veil”…. and contingency lawyers love to get such cases.

(This only applies to employees. If you own and operate the machine yourself, you can tell OSHA and the Lawyers to kiss your platen. )

Now… about the press itself: I have no idea if it’s possible. I do know that a C&P cannot be rendered OSHA compliant at a reasonable cost, but not if a Windmill can.

I truly appreciate the comments I am receiving. A little more on our current situation. The question we posed to OSHA was this. If the original manufacturer doesn’t have a guard, an engineer designs a guard, an installer modifies the original equipment to which there are no engineering specs, and the guard fails resulting in an employee injury; who is liable? Is the manufacturer, the engineer, the installer, the employer, or OSHA responsible for mandating a guard that may prove to be an additional hazard? Needless to say, the question remains unanswered.

The truly frustrating issue is retrofitting a piece of equipment that exceeds the cost of buying a machine in the first place. We may be forced to sell the equipment only to farm the jobs out to be finished on the exact same equipment at a shop who has been fortunate enough to elude an inspection.

Please keep your thoughts and ideas coming. I’m open to any suggestions.

Mike

Mike - It is VERY frustrating. Any letterpressman who has been in business for very long will have had to face it. It is exactly for issues just like this that Kluge stopped refurbishing / retrofitting older machines….. and I’d guess that it’s the reason Heidleberg does not offer guards for Windmills. The liability in today’s world is just too risky.

CFR1910 is very clear that the primary responsibility for an employee’s safety lies with the employer….. and all other potentially responsible parties are secondary.

If one adheres to the letter of the rules, then virtually ALL of our letterpresses, especially our platen presses, would have to be retired, since they cannot be effectively retrofitted. In the end we are all faced with three choices:

1- Ignore the rules and liability issues and allow employees to run the machinery (which is risky for a business)
2- Retire the machinery (which is tragic)
3- Only run the machinery ourselves, and keep employees away anything that might bite them.

In my shop, we use option 3…. but a good friend of mine takes the first option. I guess in the end, it all boils down to how much risk you are willing to take.

We won’t ignore for a multitude of reasons but will probably have to retire the machine if a variance isn’t granted. Option three would require removing the equipment from our building and having it installed off-site regardless of who ran the equipment to release any possible liability of our physical plant location which is the address on the citation.

I was wondering when this topic would appear and am curious about how it is being addressed since letterpress printing has made such a dramatic revival and these old presses are being put back in use in book arts programs where classes are being taught, and shops where letterpress products are being produced.

As I remember, somewhere between 1970 and 1980 OSHA banned schools from using platen presses. Schools were a large part of the Kelsey business and the Kelsey Company was already in a decline during that period. This was probably the beginning of the end of the company which closed in 1990.

I will be interested in following this discussion to see what experiences and suggestions are offered. Sadly, as in most other areas where safety issues are involved, the final resolution of the issues may be driven by litigation.

Hi Elizabeth,
Did OSHA ban all platen presses or just flywheel driven ones? My understanding is that it was the latter.

Daniel Morris
The Arm Letterpress
Brooklyn, NY

Daniel - Thanks for pointing out my omission. I would think it must have been just the flywheel driven presses, but that would be just a rational hunch. There must be someone here or at letpress who might have more historically accurate information. Perhaps OSHA may have felt that fingers could be mashed in the lever presses too???

Winking Cat, I stand “technicaly corrected”. :)

Eliz…. Over the week-end I researched the OSHA position on Platen Presses in schools, and several related appeals. As I can best determine, not being a lawyer, is that “any press that poses a serious pinch hazard….” cannot be used in either schools or the workplace.

Unfortunately, the definition of “serious pinch hazard” is rather subjective….. so it is unclear if lever presses are banned or not. At least it’s unclear to my limited understanding.

Even though letterpress is growing, it is still a very small segment of the industry and will most likely remain small. Given OSHA’s limited budget and grandious bureaucratic nature, it is unlikely that we’ll get any official clarification on this matter, even if we ask them point-blank what the rules are. As a result, we will remain at the mercy of the contingency lawyers and courts for a long time to come.

I think it’s a sad state of affairs.

Thanks for posting this info. I’ve never heard it put this way before, but I am going to stand by my interpretation of their policy. It would be pretty hard to hurt yourself with a C&P Pilot unless you were trying to carry it!

Daniel Morris
The Arm Letterpress
Brooklyn, NY

My company is waiting for an OSHA inspector’s finding regarding our windmill. The inspector has stated that guards will need to be installed if we are going to continue to use the press. What was the outcome for you regarding the windmill? Does anyone have information about building guards for a windmill?

Rodney Young
Young Graphics
456 Central Avenue
Lexington, NC 27292

I am in France and using 10x15 Heidelberg without guards but don’t have the public/customers through the print area.

If I did, I would install a guard like this one…

http://www.letterpressservices.com/index.php/parts/platen/platen-safety-...

A number of years ago in an open discussion at a conference this subject came up. It was pointed out that RPM’s figured into the need to completely guard a wheel or flywheel. A pinch point needs to be covered but open access to a belt or wheel below a certain RPM is allowed. Reference was made to specific OSHA regs at the time. Things change over time but it might be worth exploring what, if any, threshold there might be.

I dont know anything about Presses but couldnt you just put the press in its own little room and you the owner be the only one allowed to use it, sounds like long as no employees touch it, no one will be liable for getting injured… nor would anyone be able to be sued

Just my 2 cents

OSHA problems with my windmill “guarding” being insufficient. Has anyone had experience satisfying these people?

HELP!

This same problem comes up over here sometimes and it is usually a young inspector !!!! As long as the manufacturers guards are on as of manufacture we get away with it but one small appeasement of note is to enclose its area with a personell barrier so as to stop anyone bumping the operator into the press , other than that pray for enlightenment , i have thought on this before to produce a guard , maybe i should look into it again ,being a minder of these machines i could at least loook at it from our angle for practicality.