1910.212 General Requirements for All Machines
1910.213 Woodworking Machinery Requirements
1910.215 Abrasive Wheel Machinery.
1910.218 Forging Machines
1910.219 Mechanical Power-Transmission Apparatus
(a) General requirements. (1)-(3) [Reserved]
(b) Mechanical power press guarding and construction, general -
(c) Safeguarding the point of operation -
(d) Design, construction, setting and feeding of dies -
(e) Inspection, maintenance, and modification of presses -
(f) Operation of power presses - (1) [Reserved]
|Distance of opening from point of operation hazard||Maximum width of opening|
This table shows the distances that guards shall be positioned from the danger line in accordance with the required openings.(g) Reports of injuries to employees operating mechanical power presses.
Ds = Hs × (Ts Tp Tr 2Tm) Dp
Ds = Minimum safety distance.
Hs = Hand speed constant of 63 inches per second (1.6 m/s).
Ts = Longest press stopping time, in seconds, computed by taking averages of multiple measurements at each of three positions (45 degrees, 60 degrees, and 90 degrees) of crankshaft angular position; the longest of the three averages is the stopping time to use. (Ts is defined as the sum of the kinetic energy dissipation time plus the pneumatic/magnetic/hydraulic reaction time of the clutch/brake operating mechanism(s).)
Tp = Longest presence sensing device response time, in seconds.
Tr = Longest response time, in seconds, of all interposing control elements between the presence sensing device and the clutch/brake operating mechanism(s).
Tm = Increase in the press stopping time at the top of the stroke, in seconds, allowed by the brake monitor for brake wear. The time increase allowed shall be limited to no more than 10 percent of the longest press stopping time measured at the top of the stroke, or 10 milliseconds, whichever is longer.
Dp = Penetration depth factor, required to provide for possible penetration through the presence sensing field by fingers or hand before detection occurs. The penetration depth factor shall be determined from Graph h-1 using the minimum object sensitivity size.
(vi) The presence sensing device location shall either be set at each tool change and set-up to provide at least the minimum safety distance, or fixed in location to provide a safety distance greater than or equal to the minimum safety distance for all tooling set-ups which are to be used on that press.
(vii) Where presence sensing device location is adjustable, adjustment shall require the use of a special tool available only to authorized persons.
(viii) Supplemental safeguarding shall be used to protect all areas of access to the point of operation which are unprotected by the PSDI presence sensing device. Such supplemental safeguarding shall consist of either additional light curtain (photo-electric) presence sensing devices or other types of guards which meet the requirements of paragraphs (c) and (h) of this section.
Appendix A to § 1910.217 - Mandatory Requirements for Certification/Validation of Safety Systems for Presence Sensing Device Initiation of Mechanical Power Presses
The purpose of the certification/validation of safety systems for presence sensing device initiation (PSDI) of mechanical power presses is to ensure that the safety systems are designed, installed, and maintained in accordance with all applicable requirements of 29 CFR 1910.217 (a) through (h) and this appendix A.
The certification/validation process shall utilize an independent third-party validation organization recognized by OSHA in accordance with the requirements specified in appendix C of this section.
While the employer is responsible for assuring that the certification/validation requirements in § 1910.217(h)(11) are fulfilled, the design certification of PSDI safety systems may be initiated by manufacturers, employers, and/or their representatives. The term manufacturers refers to the manufacturer of any of the components of the safety system. An employer who assembles a PSDI safety system would be a manufacturer as well as employer for purposes of this standard and appendix.
The certification/validation process includes two stages. For design certification, in the first stage, the manufacturer (which can be an employer) certifies that the PSDI safety system meets the requirements of 29 CFR 1910.217 (a) through (h) and this appendix A, based on appropriate design criteria and tests. In the second stage, the OSHA-recognized third-party validation organization validates that the PSDI safety system meets the requirements of 29 CFR 1910.217 (a) through (h) and this appendix A and the manufacturer's certification by reviewing the manufacturer's design and test data and performing any additional reviews required by this standard or which it believes appropriate.
For installation certification/validation and annual recertification/revalidation, in the first stage the employer certifies or recertifies that the employer is installing or utilizing a PSDI safety system validated as meeting the design requirements of 29 CFR 1910.217 (a) through (h) and this appendix A by an OSHA-recognized third-party validation organization and that the installation, operation and maintenance meet the requirements of 29 CFR 1910.217 (a) through (h) and this appendix A. In the second stage, the OSHA-recognized third-party validation organization validates or revalidates that the PSDI safety system installation meets the requirements of 29 CFR 1910.217 (a) through (h) and this appendix A and the employer's certification, by reviewing that the PSDI safety system has been certified; the employer's certification, designs and tests, if any; the installation, operation, maintenance and training; and by performing any additional tests and reviews which the validation organization believes is necessary.
The certification/validation of safety systems for PSDI shall consider the press, controls, safeguards, operator, and environment as an integrated system which shall comply with all of the requirements in 29 CFR 1910.217 (a) through (h) and this appendix A. The certification/validation process shall verify that the safety system complies with the OSHA safety requirements as follows:
A. Design Certification/Validation
1. The major parts, components and subsystems used shall be defined by part number or serial number, as appropriate, and by manufacturer to establish the configuration of the system.
2. The identified parts, components and subsystems shall be certified by the manufacturer to be able to withstand the functional and operational environments of the PSDI safety system.
3. The total system design shall be certified by the manufacturer as complying with all requirements in 29 CFR 1910.217 (a) through (h) and this appendix A.
4. The third-party validation organization shall validate the manufacturer's certification under paragraphs 2 and 3.
B. Installation Certification/Validation
1. The employer shall certify that the PSDI safety system has been design certified and validated, that the installation meets the operational and environmental requirements specified by the manufacturer, that the installation drawings are accurate, and that the installation meets the requirements of 29 CFR 1910.217 (a) through (h) and this appendix A. (The operational and installation requirements of the PSDI safety system may vary for different applications.)
2. The third-party validation organization shall validate the employer's certifications that the PSDI safety system is design certified and validated, that the installation meets the installation and environmental requirements specified by the manufacturer, and that the installation meets the requirements of 29 CFR 1910.217 (a) through (h) and this appendix A.
1. The PSDI safety system shall remain under certification/validation for the shorter of one year or until the system hardware is changed, modified or refurbished, or operating conditions are changed (including environmental, application or facility changes), or a failure of a critical component has occurred.
2. Annually, or after a change specified in paragraph 1., the employer shall inspect and recertify the installation as meeting the requirements set forth under B., Installation Certification/Validation.
3. The third-party validation organization, annually or after a change specified in paragraph 1., shall validate the employer's certification that the requirements of paragraph B., Installation Certification/Validation have been met.
(Note: Such changes in operational conditions as die changes or press relocations not involving disassembly or revision to the safety system would not require recertification/revalidation.)
A. General Design Certification/Validation Requirements
1. Certification/Validation Program Requirements. The manufacturer shall certify and the OSHA-recognized third-party validation organization shall validate that:
(a) The design of components, subsystems, software and assemblies meets OSHA performance requirements and are ready for the intended use; and
(b) The performance of combined subsystems meets OSHA's operational requirements.
2. Certification/Validation Program Level of Risk Evaluation Requirements. The manufacturer shall evaluate and certify, and the OSHA-recognized third-party validation organization shall validate, the design and operation of the safety system by determining conformance with the following:
a. The safety system shall have the ability to sustain a single failure or a single operating error and not cause injury to personnel from point of operation hazards. Acceptable design features shall demonstrate, in the following order or precedence, that:
Appendix B to § 1910.217 - Nonmandatory Guidelines for Certification/Validation of Safety Systems for Presence Sensing Device Initiation of Mechanical Power Presses
This appendix provides employers, manufacturers, and their representatives, with nonmandatory guidelines for use in developing certification documents. Employers and manufacturers are encouraged to recommend other approaches if there is a potential for improving safety and reducing cost. The guidelines apply to certification/validation activity from design evaluation through the completion of the installation test and the annual recertification/revalidation tests.
A. The certification/validation process should confirm that hazards identified by hazard analysis, (HA), failure mode effect analysis (FMEA), and other system analyses have been eliminated by design or reduced to an acceptable level through the use of appropriate design features, safety devices, warning devices, or special procedures. The certification/validation process should also confirm that residual hazards identified by operational analysis are addressed by warning, labeling safety instructions or other appropriate means.
B. The objective of the certification/validation program is to demonstrate and document that the system satisfies specification and operational requirements for safe operations.
The safety attributes of a certified/validated PSDI safety system are more likely to be maintained if the quality of the system and its parts, components and subsystem is consistently controlled. Each manufacturer supplying parts, components, subsystems, and assemblies needs to maintain the quality of the product, and each employer needs to maintain the system in a non-degraded condition.
A. Certification/validation of hardware design below the system level should be accomplished by test and/or analysis.
B. Analytical methods may be used in lieu of, in combination with, or in support of tests to satisfy specification requirements.
C. Analyses may be used for certification/validation when existing data are available or when test is not feasible.
D. Similarity analysis may be used in lieu of tests where it can be shown that the article is similar in design, manufacturing process, and quality control to another article that was previously certified/validated in accordance with equivalent or more stringent criteria. If previous design, history and application are considered to be similar, but not equal to or more exacting than earlier experiences, the additional or partial certification/validation tests should concentrate on the areas of changed or increased requirements.
The analysis reports should identify: (1) The basis for the analysis; (2) the hardware or software items analyzed; (3) conclusions; (4) safety factors; and (5) limit of the analysis. The assumptions made during the analysis should be clearly stated and a description of the effects of these assumptions on the conclusions and limits should be included.
Certification/validation by similarity analysis reports should identify, in addition to the above, application of the part, component or subsystem for which certification/validation is being sought as well as data from previous usage establishing adequacy of the item. Similarity analysis should not be accepted when the internal and external stresses on the item being certified/validated are not defined.
Usage experience should also include failure data supporting adequacy of the design.
Appendix C to § 1910.217 - Mandatory Requirements for OSHA Recognition of Third-Party Validation Organizations for the PSDI Standard
This appendix prescribes mandatory requirements and procedures for OSHA recognition of third-party validation organizations to validate employer and manufacturer certifications that their equipment and practices meet the requirements of the PSDI standard. The scope of the appendix includes the three categories of certification/validation required by the PSDI standard: Design Certification/Validation, Installation Certification/Validation, and Annual Recertification/Revalidation.
If further detailing of these provisions will assist the validation organization or OSHA in this activity, this detailing will be done through appropriate OSHA Program Directives.
I. Procedure for OSHA Recognition of Validation Organizations
1. Eligibility. a. Any person or organization considering itself capable of conducting a PSDI-related third-party validation function may apply for OSHA recognition.
b. However, in determining eligibility for a foreign-based third-party validation organization, OSHA shall take into consideration whether there is reciprocity of treatment by the foreign government after consultation with relevant U.S. government agencies.
2. Content of application. a. The application shall identify the scope of the validation activity for which the applicant wishes to be recognized, based on one of the following alternatives:
B. Review and Decision Process
1. Acceptance and field inspection. All applications submitted will be accepted by OSHA, and their receipt acknowledged in writing. After receipt of an application, OSHA may request additional information if it believes information relevant to the requirements for recognition have been omitted. OSHA may inspect the facilities of the third-party validation organization and any validating laboratory, and while there shall review any additional documentation underlying the application. A report shall be made of each field inspection.
2. Requirements for recognition. The requirements for OSHA recognition of a third-party validation organization for the PSDI standard are that the program has fulfilled the requirements of section II of this appendix for qualifications and of section III of this appendix for program requirements, and the program has identified appropriate test and analysis methods to meet the requirements of the PSDI standard and appendix A.
3. Preliminary approval. If, after review of the application, any additional information, and the inspection report, the applicant and any validating laboratory appear to have met the requirements for recognition, a written recommendation shall be submitted by the responsible OSHA personnel to the Assistant Secretary to approve the application with a supporting explanation.
4. Preliminary disapproval. If, after review of the application, additional information, and inspection report, the applicant does not appear to have met the requirements for recognition, the Director of the PSDI certification/validation program shall notify the applicant in writing, listing the specific requirements of this appendix which the applicant has not met, and the reasons.
5. Revision of application. After receipt of a notification of preliminary disapproval, the applicant may submit a revised application for further review by OSHA pursuant to subsection I.B. of this appendix or may request that the original application be submitted to the Assistant Secretary with a statement of reasons supplied by the applicant as to why the application should be approved.
6. Preliminary decision by Assistant Secretary. a. The Assistant Secretary, or a special designee for this purpose, will make a preliminary decision whether the applicant has met the requirements for recognition based on the completed application file and the written staff recommendation, as well as the statement of reasons by the applicant if there is a recommendation of disapproval.
b. This preliminary decision will be sent to the applicant and subsequently published in the Federal Register.
7. Public review and comment period. a. The Federal Register notice of preliminary decision will provide a period of not less than 60 calendar days for the written comments on the applicant's fulfillment of the requirements for recognition. The application, supporting documents, staff recommendation, statement of applicant's reasons, and any comments received, will be available for public inspection in the OSHA Docket Office.
b. If the preliminary decision is in favor of recognition, a member of the public, or if the preliminary decision is against recognition, the applicant may request a public hearing by the close of the comment period, if it supplies detailed reasons and evidence challenging the basis of the Assistant Secretary's preliminary decision and justifying the need for a public hearing to bring out evidence which could not be effectively supplied through written submissions.
8. Final decision by Assistant Secretary - a. Without hearing. If there are no valid requests for a hearing, based on the application, supporting documents, staff recommendation, evidence and public comment, the Assistant Secretary shall issue the final decision (including reasons) of the Department of Labor on whether the applicant has demonstrated by a preponderance of the evidence that it meets the requirements for recognition.
b. After hearing. If there is a valid request for a hearing pursuant to paragraph I.B.7.b. of this appendix, the following procedures will be used:
C. Terms and Conditions of Recognition, Renewal and Revocation
1. The following terms and conditions shall be part of every recognition:
a. The recognition of any validation organization will be evidenced by a letter of recognition from OSHA. The letter will provide the specific details of the scope of the OSHA recognition as well as any conditions imposed by OSHA, including any Federal monitoring requirements.
b. The recognition of each validation organization will be valid for five years, unless terminated before or renewed after the expiration of the period. The dates of the period of recognition will be stated in the recognition letter.
c. The recognized validation organization shall continue to satisfy all the requirements of this appendix and the letter of recognition during the period of recognition.
2. A recognized validation organization may change a test method of the PSDI safety system certification/validation program by notifying the Assistant Secretary of the change, certifying that the revised method will be at least as effective as the prior method, and providing the supporting data upon which its conclusions are based.
3. A recognized validation organization may renew its recognition by filing a renewal request at the address in paragraph I.A.3. of this appendix, above, not less than 180 calendar days, nor more than one year, before the expiration date of its current recognition. When a recognized validation organization has filed such a renewal request, its current recognition will not expire until a final decision has been made on the request. The renewal request will be processed in accordance with subsection I.B. of this appendix, above, except that a reinspection is not required but may be performed by OSHA. A hearing will be granted to an objecting member of the public if evidence of failure to meet the requirements of this appendix is supplied to OSHA.
4. A recognized validation organization may apply to OSHA for an expansion of its current recognition to cover other categories of PSDI certification/validation in addition to those included in the current recognition. The application for expansion will be acted upon and processed by OSHA in accordance with subsection I.B. of this appendix, subject to the possible reinspection exception. If the validation organization has been recognized for more than one year, meets the requirements for expansion of recognition, and there is no evidence that the recognized validation organization has not been following the requirements of this appendix and the letter of recognition, an expansion will normally be granted. A hearing will be granted to an objecting member of the public only if evidence of failure to meet the requirements of this appendix is supplied to OSHA.
5. A recognized validation organization may voluntarily terminate its recognition, either in its entirety or with respect to any area covered in its recognition, by giving written notice to OSHA at any time. The written notice shall indicate the termination date. A validation organization may not terminate its installation certification and recertification validation functions earlier than either one year from the date of the written notice, or the date on which another recognized validation organization is able to perform the validation of installation certification and recertification.
6.a. OSHA may revoke its recognition of a validation organization if its program either has failed to continue to satisfy the requirements of this appendix or its letter of recognition, has not been performing the validation functions required by the PSDI standard and appendix A, or has misrepresented itself in its applications. Before proposing to revoke recognition, the Agency will notify the recognized validation organization of the basis of the proposed revocation and will allow rebuttal or correction of the alleged deficiencies. If the deficiencies are not corrected, OSHA may revoke recognition, effective in 60 days, unless the validation organization requests a hearing within that time.
b. If a hearing is requested, it shall be held before an administrative law judge of the Department of Labor pursuant to the rules specified in 29 CFR part 1905, subpart C.
c. The parties shall be OSHA and the recognized validation organization. The decision shall be made pursuant to the procedures specified in paragraphs I.B.8.b.(2) through (4) of this appendix except that the burden of proof shall be on OSHA to demonstrate by a preponderance of the evidence that the recognition should be revoked because the validation organization either is not meeting the requirements for recognition, has not been performing the validation functions required by the PSDI standard and appendix A, or has misrepresented itself in its applications.
D. Provisions of OSHA Recognition
Each recognized third-party validation organization and its validating laboratories shall:
1. Allow OSHA to conduct unscheduled reviews or on-site audits of it or the validating laboratories on matters relevant to PSDI, and cooperate in the conduct of these reviews and audits;
2. Agree to terms and conditions established by OSHA in the grant of recognition on matters such as exchange of data, submission of accident reports, and assistance in studies for improving PSDI or the certification/validation process.
The third-party validation organization, the validating laboratory, and the employees of each shall meet the requirements set forth in this section of this appendix.
A. Experience of Validation Organization
1. The third-party validation organization shall have legal authority to perform certification/validation activities.
2. The validation organization shall demonstrate competence and experience in either power press design, manufacture or use, or testing, quality control or certification/validation of equipment comparable to power presses and associated control systems.
3. The validation organization shall demonstrate a capability for selecting, reviewing, and/or validating appropriate standards and test methods to be used for validating the certification of PSDI safety systems, as well as for reviewing judgements on the safety of PSDI safety systems and their conformance with the requirements of this section.
4. The validating organization may utilize the competence, experience, and capability of its employees to demonstrate this competence, experience and capability.
B. Independence of Validation Organization
1. The validation organization shall demonstrate that:
a. It is financially capable to conduct the work;
b. It is free of direct influence or control by manufacturers, suppliers, vendors, representatives of employers and employees, and employer or employee organizations; and
c. Its employees are secure from discharge resulting from pressures from manufacturers, suppliers, vendors, employers or employee representatives.
2. A validation organization may be considered independent even if it has ties with manufacturers, employers or employee representatives if these ties are with at least two of these three groups; it has a board of directors (or equivalent leadership responsible for the certification/validation activities) which includes representatives of the three groups; and it has a binding commitment of funding for a period of three years or more.
C. Validating Laboratory
The validation organization's laboratory (which organizationally may be a part of the third-party validation organization):
1. Shall have legal authority to perform the validation of certification;
2. Shall be free of operational control and influence of manufacturers, suppliers, vendors, employers, or employee representatives that would impair its integrity of performance; and
3. Shall not engage in the design, manufacture, sale, promotion, or use of the certified equipment.
D. Facilities and Equipment
The validation organization's validating laboratory shall have available all testing facilities and necessary test and inspection equipment relevant to the validation of the certification of PSDI safety systems, installations and operations.
The validation organization and the validating laboratory shall be adequately staffed by personnel who are qualified by technical training and/or experience to conduct the validation of the certification of PSDI safety systems.
1. The validation organization shall assign overall responsibility for the validation of PSDI certification to an Administrative Director. Minimum requirements for this position are a Bachelor's degree and five years professional experience, at least one of which shall have been in responsible charge of a function in the areas of power press design or manufacture or a broad range of power press use, or in the areas of testing, quality control, or certification/validation of equipment comparable to power presses or their associated control systems.
2. The validating laboratory, if a separate organization from the validation organization, shall assign technical responsibility for the validation of PSDI certification to a Technical Director. Minimum requirements for this position are a Bachelor's degree in a technical field and five years of professional experience, at least one of which shall have been in responsible charge of a function in the area of testing, quality control or certification/validation of equipment comparable to power presses or their associated control systems.
3. If the validation organization and the validating laboratory are the same organization, the administrative and technical responsibilities may be combined in a single position, with minimum requirements as described in E.1. and 2. for the combined position.
4. The validation organization and validating laboratory shall have adequate administrative and technical staffs to conduct the validation of the certification of PSDI safety systems.
F. Certification/Validation Mark or Logo
1. The validation organization or the validating laboratory shall own a registered certification/validation mark or logo.
2. The mark or logo shall be suitable for incorporation into the label required by paragraph (h)(11)(iii) of this section.
III. Program Requirements
A. Test and Certification/Validation Procedures
1. The validation organization and/or validating laboratory shall have established written procedures for test and certification/validation of PSDI safety systems. The procedures shall be based on pertinent OSHA standards and test methods, or other publicly available standards and test methods generally recognized as appropriate in the field, such as national consensus standards or published standards of professional societies or trade associations.
2. The written procedures for test and certification/validation of PSDI systems, and the standards and test methods on which they are based, shall be reproducible and be available to OSHA and to the public upon request.
B. Test Reports
1. A test report shall be prepared for each PSDI safety system that is tested. The test report shall be signed by a technical staff representative and the Technical Director.
2. The test report shall include the following:
a. Name of manufacturer and catalog or model number of each subsystem or major component.
b. Identification and description of test methods or procedures used. (This may be through reference to published sources which describe the test methods or procedures used.)
c. Results of all tests performed.
d. All safety distance calculations.
3. A copy of the test report shall be maintained on file at the validation organization and/or validating laboratory, and shall be available to OSHA upon request.
C. Certification/Validation Reports
1. A certification/validation report shall be prepared for each PSDI safety system for which the certification is validated. The certification/validation report shall be signed by the Administrative Director and the Technical Director.
2. The certification/validation report shall include the following:
a. Name of manufacturer and catalog or model number of each subsystem or major component.
b. Results of all tests which serve as the basis for the certification.
c. All safety distance calculations.
d. Statement that the safety system conforms with all requirements of the PSDI standard and appendix A.
3. A copy of the certification/validation report shall be maintained on file at the validation organization and/or validating laboratory, and shall be available to the public upon request.
4. A copy of the certification/validation report shall be submitted to OSHA within 30 days of its completion.
D. Publications System
The validation organization shall make available upon request a list of PSDI safety systems which have been certified/validated by the program.
E. Follow-up Activities
1. The validation organization or validating laboratory shall have a follow-up system for inspecting or testing manufacturer's production of design certified/validated PSDI safety system components and subassemblies where deemed appropriate by the validation organization.
2. The validation organization shall notify the appropriate product manufacturer(s) of any reports from employers of point of operation injuries which occur while a press is operated in a PSDI mode.
The validation organization or validating laboratory shall maintain a record of each certification/validation of a PSDI safety system, including manufacturer and/or employer certification documentation, test and working data, test report, certification/validation report, any follow-up inspections or testing, and reports of equipment failures, any reports of accidents involving the equipment, and any other pertinent information. These records shall be available for inspection by OSHA and OSHA State Plan offices.
G. Dispute Resolution Procedures
1. The validation organization shall have a reasonable written procedure for acknowledging and processing appeals or complaints from program participants (manufacturers, producers, suppliers, vendors and employers) as well as other interested parties (employees or their representatives, safety personnel, government agencies, etc.), concerning certification or validation.
2. The validation organization may charge any complainant the reasonable charge for repeating tests needed for the resolution of disputes.
Appendix D to § 1910.217 - Nonmandatory Supplementary Information
This appendix provides nonmandatory supplementary information and guidelines to assist in the understanding and use of 29 CFR 1910.217(h) to allow presence sensing device initiation (PSDI) of mechanical power presses. Although this appendix as such is not mandatory, it references sections and requirements which are made mandatory by other parts of the PSDI standard and appendices.
OSHA intends that PSDI continue to be prohibited where present state-of-the-art technology will not allow it to be done safely. Only part revolution type mechanical power presses are approved for PSDI. Similarly, only presses with a configuration such that a person's body cannot completely enter the bed area are approved for PSDI.
2. Brake and Clutch
Flexible steel band brakes do not possess a long-term reliability against structural failure as compared to other types of brakes, and therefore are not acceptable on presses used in the PSDI mode of operation.
Fast and consistent stopping times are important to safety for the PSDI mode of operation. Consistency of braking action is enhanced by high brake torque. The requirement in paragraph (h)(2)(ii) defines a high torque capability which should ensure fast and consistent stopping times.
Brake design parameters important to PSDI are high torque, low moment of inertia, low air volume (if pneumatic) mechanisms, non-interleaving engagement springs, and structural integrity which is enhanced by over-design. The requirement in paragrpah (h)(2)(iii) reduces the possibility of significantly increased stopping time if a spring breaks.
As an added precaution to the requirements in paragraph (h)(2)(iii), brake adjustment locking means should be secured. Where brake springs are externally accessible, lock nuts or other means may be provided to reduce the possibility of backing off of the compression nut which holds the springs in place.
3. Pneumatic Systems
Elevated clutch/brake air pressure results in longer stopping time. The requirement in paragraph (h)(3)(i)(C) is intended to prevent degradation in stoping speed from higher air pressure. Higher pressures may be permitted, however, to increase clutch torque to free “jammed” dies, provided positive measures are provided to prevent the higher pressure at other times.
4. Flywheels and Bearings
Lubrication of bearings is considered the single greatest deterrent to their failure. The manufacturer's recommended procedures for maintenance and inspection should be closely followed. 5. Brake Monitoring
The approval of brake monitor adjustments, as required in paragraph (h)(5)(ii), is not considered a recertification, and does not necessarily involve an on-site inspection by a representative of the validation organization. It is expected that the brake monitor adjustment normally could be evaluated on the basis of the effect on the safety system certification/validation documentation retained by the validation organization.
Use of a brake monitor does not eliminate the need for periodic brake inspection and maintenance to reduce the possibility of catastrophic failures.
6. Cycle Control and Control Systems
The PSDI set-up/reset means required by paragraph (h)(6)(iv) may be initiated by the actuation of a special momentary pushbutton or by the actuation of a special momentary pushbutton and the initiation of a first stroke with two hand controls.
It would normally be preferable to limit the adjustment of the time required in paragraph (h)(6)(vi) to a maximum of 15 seconds. However, where an operator must do many operations outside the press, such as lubricating, trimming, deburring, etc., a longer interval up to 30 seconds is permitted.
When a press is equipped for PSDI operation, it is recommended that the presence sensing device be active as a guarding device in other production modes. This should enhance the reliability of the device and ensure that it remains operable.
An acceptable method for interlocking supplemental guards as required by paragraph (h)(6)(xiii) would be to incorporate the supplemental guard and the PSDI presence sensing device into a hinged arrangement in which the alignment of the presence sensing device serves, in effect, as the interlock. If the supplemental guards are moved, the presence sensing device would become misaligned and the press control would be deactivated. No extra microswitches or interlocking sensors would be required.
Paragraph (h)(6)(xv) of the standard requires that the control system have provisions for an “inch” operating means; that die-setting not be done in the PSDI mode; and that production not be done in the “inch” mode. It should be noted that the sensing device would be by-passed in the “inch” mode. For that reason, the prohibitions against die-setting in the PSDI mode, and against production in the “inch” mode are cited to emphasize that “inch” operation is of reduced safety and is not compatible with PSDI or other production modes.
7. Environmental Requirements
It is the intent of paragraph (h)(7) that control components be provided with inherent design protection against operating stresses and environmental factors affecting safety and reliability.
8. Safety system
The safety system provision continues the concept of paragraph (b)(13) that the probability of two independent failures in the length of time required to make one press cycle is so remote as to be a negligible risk factor in the total array of equipment and human factors. The emphasis is on an integrated total system including all elements affecting point of operation safety.
It should be noted that this does not require redundancy for press components such as structural elements, clutch/brake mechanisms, plates, etc., for which adequate reliability may be achieved by proper design, maintenance, and inspection.
9. Safeguarding the Point of Operation
The intent of paragraph (h)(9)(iii) is to prohibit use of mirrors to “bend” a single light curtain sensing field around corners to cover more than one side of a press. This prohibition is needed to increase the reliability of the presence sensing device in initiating a stroke only when the desired work motion has been completed.
Object sensitivity describes the capability of a presence sensing device to detect an object in the sensing field, expressed as the linear measurement of the smallest interruption which can be detected at any point in the field. Minimum object sensitivity describes the largest acceptable size of the interruption in the sensing field. A minimum object sensitivity of one and one-fourth inches (31.75 mm) means that a one and one-fourth inch (31.75 mm) diameter object will be continuously detected at all locations in the sensing field.
In deriving the safety distance required in paragraph (h)(9)(v), all stopping time measurements should be made with clutch/brake air pressure regulated to the press manufacturer's recommended value for full clutch torque capability. The stopping time measurements should be made with the heaviest upper die that is planned for use in the press. If the press has a slide counterbalance system, it is important that the counterbalance be adjusted correctly for upper die weight according to the manufacturer's instructions. While the brake monitor setting is based on the stopping time it actually measures, i.e., the normal stopping time at the top of the stroke, it is important that the safety distance be computed from the longest stopping time measured at any of the indicated three downstroke stopping positions listed in the explanation of Ts. The use in the formula of twice the stopping time increase, Tm, allowed by the brake monitor for brake wear allows for greater increases in the downstroke stopping time than occur in normal stopping time at the top of the stroke.
10. Inspection and Maintenance. [RESERVED]
11. Safety System Certification/Validation
Mandatory requirements for certification/validation of the PSDI safety system are provided in appendix A and appendix C to this standard. Nonmandatory supplementary information and guidelines relating to certification/validation of the PSDI safety system are provided to appendix B to this standard.