OSHA and C & P’s…are they illegal?

I would like to bring up the subject that was previously discussed in this post
http://www.briarpress.org/18198 (scroll all the way to the bottom)
as I would like to some day open a stationery shop / retail shop and somehow have the machines in view. I’m curious to find out the exact law regarding the use of a motorized or treadle operated C & P. I understand that having them in a school would be a problem, but can you have them in a shop where people can see them? Does anyone know the exact terms of this law?

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High school students use power machinery all the time in schools. I have a chop saw in my art room, a metal lathe, drill presses, grinders, a milling machine, foundry, forge, kiln, plate shear, etc. OSHA and the insurance inspector want proper guards on every tool. If proper guards cannot be found, they must be fabricated.

On the bright side, with proper guards, the machinery is welcome. Teachers must understand the safety precautions and educate and test their students before a student is allowed to use machinery. If a machine has appropriate guards, and the student is educated, accidents will still happen, but the school is not liable.

Your shop will have similar liability issues. Usually a sign that denotes work space and customer space will suffice. Customers then enter the work space with no expectation of personal safety.

Quoting from OSHA’S website:
Exemptions. The following employers are not covered by the OSH Act:
SELF-EMPLOYED PERSONS****(see footnote)
farms at which only immediate members of the farmer’s family are employed
those whose working conditions are regulated by other federal agencies under other federal statutes (This includes most employment in mining, nuclear energy and nuclear weapons manufacture, and many segments of the transportation industries.)
persons who employ others in their own homes to perform domestic services such as housecleaning and child care
churches and nonsecular church activities
states and political subdivisions (although some state plans cover public employees)
employers not engaged in interstate commerce (Interstate commerce is defined so broadly that it covers almost all economic activity in the United States. If you, as an employer, purchase materials that came from out of state or use the telephone or mails, you are engaging in interstate commerce for purposes of this Act.)
****I interpret this as….If you own the press you can operate it. When you hire someone to run it…YOU ARE ILLEGAL!

Erica- I’d recommend that you call OSHA. They’ll send a representative out, maybe take a few days or weeks to ponder the situation, and then tell you that the machine cannot be rendered OSHA compliant….. and your Worker’s Comp carrier will tell you the same thing.

Boundstaff is only partly correct in his comment. If properly guarded, many machines can be rendered OSHA compliant. This includes a lot of machines that can cut off fingers or cause nasty burns. Unfortunately, the Federal Government has decided that a flywheel-operated, hand-fed platen press cannot be “properly guarded.” By their very nature these machines require that the operator be exposed to a crush hazard that they feel is unacceptable.

In this particular instance, OUR opinions are not important. We can debate their relative safety all day long, but that does not alter the OSHA rules. They are what they are….. and if you disagree with them, I’d recommend that you discuss it with OSHA.

Also… Stan is right….. “****I interpret this as….If you own the press you can operate it. When you hire someone to run it…YOU ARE ILLEGAL!” That is the best way to say it. An employee of any business cannot legally operate a flywheel operated C&P as part of his employment in the United Sates.

Now… that being said, is there a good work-around for this legal issue? Yes, there are several work-arounds that are in common use in letterpress shops across the country:

1. As the owner of a small enterprise, you can run the press yourself, and never have an employee run it. If you can convince the OSHA guy that no employee will ever run it, sometimes they will leave you alone. (Your insurance may still not cover you… but that’s another discussion)

2. You can use a lever operated press like a Pilot. Even though they can also bite you, OSHA seems to like ‘em and doesn’t get all freaky when they see them in operation.

3. You can ignore the law and do what you please. If you are financially able to cover the risk of your own medical expenses, any OSHA fines, and the combined legal / medical costs of an injured employee….. then you can do whatever you want.

4. OR you can simply hope that nothing happens. (I don’t recommend that you follow that course of action, but many shops do.)

One final note on the subject: IF you run your shop in compliance with OSHA guidelines and someone gets hurt then the Worker’s Comp laws will limit the amount of money you or your insurance company must pay out. However, if you run a shop that is non-compliant and someone gets injured, they can claim gross negligence sue you for anything that they can convince a jury to award them. It’s a scarey prospect.

I would like to add one further option of what can be done: You can make the machine safe.OSHA and others have rules, but if you can demonstrate that your machine, with your modifications is safe, then I can not see how they could withold permission or whatever the exception document is called. A flywheel holds stored energy, no different from air or hydraulic accumulator equipped systems. For those systems we make them safe by applying a dump-valve for fast shutdown. A flywheel system can be brought to a fast stop with a mechanical failsafe actuator acting on a brake.
I think it has more to do with trying to maintain the quaint original look of the machine. In my case I have decided that my own welfare is more important than looks. But then I also decided (with help of the people on this forum) that I would rather buy a larger, newer machine than a pretty older one. My solution starts out with a variable speed drive, which requires a modern motor. Rather then repeat the whole story here, look at my blog: http://artletterpress.blogspot.com to have a look at my reasoning. I’d be interested in any feedback. Like I said, I’m just starting.

Hugo…. in theory you are right. If you can create a failsafe way to stop the machine prior to it closing on an errant finger, then you may be able to convince OSHA to allow you operate it. It would however be quite an engineering challenge to do so. Kluge tried to accomplish this with retro-fits on older equipment for a time, and ultimately gave up.

The problem is that the motion of placing paper onto the platen requires that the operator’s fingertips be at least momentarily located where they can be pinched…. so a simple guard will not suffice. Nor will a simple shut down sensor, like a laser-beam, that trips whenever a finger crosses it since at some point in the cycle a finger must cross it in order to feed the paper.

Your idea of a brake might work…. but to make it work, you will need a sensor of some sort, combined with a timing system to determine if an errant finger is in the mechanism later than a pre-determined “safe window”. Then your brake will have to work very quickly and positively….. in something like .125 to .25 seconds, depending on the speed of the machine. This would have to be a quite powerful brake, since there is a lot of energy stored in the flywheel. Stopping it in less than half a second would place a great deal of strain on the framework of the machine, so it would probably have to be reinforced.

So…. you are right. Given modern engineering methods, electronic control mechanisms, and hydraulics…. I suppose that it IS possible to build an OSHA compliant flywheel operated letterpress. However, such a machine would have little resemblance to a traditional press, and would probably not appeal to the bulk of the letterpress operators, and would be quite costly.

Thinking about it…. I DO have an idea that might work better: Instead of stopping the press, you could build an eccentic into the platen pivot that would act as a throw-out….. but instead of throwing out 1/4 inch, it would throw out maybe two or three inches with a 90degree turn of the shaft. THEN combine that with the laser sensor and timing mechanism…. and viola: the press doesn’t come to a stop, but instead just doesn’t close far enough to smash your hand. Again… it would work, but it would be rather challenging to engineer, and would most likely require building an entirely new press.

I do wish you luck in your efforts, and I hope that you do accomplish your goal. Until you do however, it is still illegal for an employee to operate a flywheel operated platen press in the United States.

There were effective safety attachments on European art platens a century ago. Even light platens like the Vicobold had it as an option. It was an easier task given their clutched flywheels and the design of the inking system. In the attached picture you can see the grill suspended in front of the inking cylinder, and a start/stop lever to the left (where the C&P has an impression throwoff lever). A finger coming between grill and platen as it closed would force the grill against the stop lever, stopping the press motion.
With the clutched flywheel, the motor continues to turn, but the press stops quickly. My Victoria stops in an inch or two without any brake, might be less if I tried to adjust the clutch. If the safety grill was ever present on this machine, earlier pressmen removed it. Of course.
Another approach is the idler pulley used on overhead flatbelt drive, and many American art platens (such as the Colt’s Armory) had the belt shifter connected to the brake so one push of the lever would stop the press. I have also seen the brake lever connected to an electrical contact to stop the motor as the press was braked.
I agree, it is a challenge to fit anything like this to a C&P but it is not impossible. Idler pulleys and brakes might be an effective solution.

image: Vicoboldlighthandplaten.jpg


PI- the idea of a clutch is a good one, especially if combined with a brake to stop the platen quickly. It could work. I also agree that it would be better to work with a lighter press. A Kelsey Star could easliy be braked fast enough to be effective. (Besides, Kelsey Stars are great presses.)

The Colt Armory brake is not that effective, though. One push of the lever would indeed stop the press, but not fast enough to act as a safety device.

Winking cat, I don’t know if you looked at my blog - on one of the recent posts I quantified my plans - and I did not feel like retyping it all here. You are right in that a timing mechanism is required, but that is simply accomplished with a little sensor. My press is likely larger than average and has quite a heavy flywheel. I decided to run at 1000IPH to give myself more time with the platen open, and also drive down to 40% speed when the platen opens, to give even more time. That way if there is a need for emergency stop it will be at vastly reduced speed. The timing you mention means you are running your press at a speed that I (at least for now) would be uncomfortable with anyway. The big question will be answered when I can experiment with dynamic breaking. Failing that, I would not be adverse to fitting a disk brake on the drive shaft, but that will require a whole lot more experimentation to arrive at a mechanically safe stop timing. For now I have a whole lot of rust to remove…