Rise in Automatic Screen Press Violations – Time to Take Action!

With the change in OSHA's enforcement policies at the beginning of this year, there has been a resurgence in the number of inspections occurring at screen printing operations. These inspections have resulted in citations with high proposed penalties. In essence, OSHA’s revisions to their enforcement policies are designed to allow each violation to be itemized with its own penalty and not what had been historically done, which was to group similar or the same violations together and issue a single penalty. Coupled with OSHA’s annual increase in penalties, the total fines being proposed started at $10,000 and some have ranged up to $35,000.

The resurgence of inspections is being driven by several factors: 

• Employee complaints – By law, OSHA must respond to any employee complaint if the person making the complaint identifies themselves. If the complaint involves a potentially serious situation, OSHA will dispatch an inspector to the facility.
• Reported injuries – OSHA requires all employers to report within 24 hours any workplace related injury or illness that requires hospitalization for treatment, any amputation, or injury that causes the loss of an eye. Any fatality must be reported within 8 hours of discovery.
• National Emphasis Program – The printing industry is considered a high hazard industry due to a high amputation rate which means OSHA will randomly inspect printing operations with a focus on machine guarding and lockout/tagout.

These factors have resulted in screen printing operations being inspected, cited, and fined for violations of several OSHA regulations. There seems to be a real focus on printing operations with automatic screen printing presses.

The companies receiving citations are reflective of the most common violations found in printing operations. Each year the Alliance publishes the top 10 OSHA violations and the recent citations are for alleged violations that are in the top 5. Here is the list of the ones being cited:

1. Hazard communication (29 CFR 1910.1200) OSHA’s Hazard Communication Standard (HCS) requires information be communicated to employees about the chemical hazards they are exposed to and protective measures to ensure their health and safety. Common citations include not having a written program, safety data sheets for all chemicals, employee training and secondary container labels.
2. Lockout/Tagout (29 CFR 1910.147) The lockout/tagout regulation protects employees from unexpected machine startups or hazardous releases during servicing and maintenance. Failing to lockout equipment, have a written program and conducting annual inspections of machine-specific procedures are the most common violations.
3. Machine guarding (29 CFR 1910.212) OSHA has several standards to protect employees from exposure to hazards such as, ingoing nip points, point of operation, flying sparks and chips, and other moving components. This regulation requires that physical guards be provided to protect employees from exposure and contact with the hazards associated with moving parts.
4. Powered industrial trucks (29 CFR 1910.178) Employees that operate forklifts or other industrial-powered vehicles, such as pallet jacks, must be initially trained, certified, and reevaluated every three years. Safety violations include improper vehicle use, lack of training and failing to recertify operators every three years.
5. Personal protective equipment (29 CFR 1910.132) OSHA requires all employers to conduct a formal written workplace hazard assessment to determine what personal protective equipment is required to protect employees from injuries. In addition, employers are required to provide personal protective equipment and provide employee training in its proper use. Failure to conduct the assessment and certify it is a commonly overlooked requirement.

Violations of the regulations addressing machine safety - lockout/tagout standard and machine guarding have generated the highest penalties. This is due to the fact that improper or no guarding, safe work practices for makeready, as well as servicing and maintenance, can result in severe injuries such as amputations, crushing, broken bones, and fatalities.

To survive an OSHA inspection, it is critical to have proper formal safety procedures, training, and documentation of the training. The lack of these makes it difficult to demonstrate that employees have been trained to perform their job in a safe manner. OSHA usually takes a very narrow interpretation in that “if it is not documented, then it did not happen”. Realizing that on-the-job training is very common in printing operations, it is important to document the training and expectations using policies, standard operating procedures, and other written approaches where the employee acknowledges receiving the training by signing a form.

PRINTING United Alliance can help members meet these requirements. The Alliance’s Government Affairs Department has many resources, such as written program templates, designed to assist printing operations and their compliance programs. These can be found on the Alliance’s website under the Safety & Health tab.

The iLEARNING+ platform now offers a training course on machine guarding and two courses on lockout/tagout. The first lockout/tagout course teaches essential requirements for all employees in the operation of equipment, and the second applies to authorized employees who need more in-depth training.

Alliance members with automatic screen printing presses are encouraged to contact either Gary Jones at gjones@printing.org or Sara Osorio at sosorio@printing.org about what is occurring with these particular types of presses.

In this article, Gary Jones, VP EHS Affairs, PRINTING United Alliance addresses OSHA compliance. More information about OSHA can be found at https://www.printing.org/library/business-excellence/environmental-health-safety/safety-health  or reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org. 

To become a member of PRINTING United Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.