By Janet L. Keyes, CIH and Carol A. Keyes, CSP
Most of the tools in your shop are probably owned by your technicians. But you provide some. And because the tools are in your shop, you have responsibility for their safe use. Seems unfair? Employees work under your direction and control. OSHA explicitly states that “Each employer shall be responsible for the safe condition of tools and equipment used by employees, including tools and equipment which may be furnished by employees.”
If an employee has a heat gun with a cord so damaged that it is held together with electrical tape, don’t allow its use in your shop. The employee is free to take it home (while you certainly don’t want him to electrocute himself at home, you don’t have control there). But if he uses it in your shop and is shocked, you’ll pay for his injuries.
The requirements aren’t complicated:
- Keep tools in good condition.
- Electrical tools have to be grounded or double-insulated.
- Keep guards in place and correctly adjusted.
- Follow the manufacturer’s instructions.
Tools need to be kept in good condition. The most common problems we see are to electrical cords and plugs. If the grounding pin breaks off or the cord insulation is damaged, the risk of shock or fire increases and the tool shouldn’t be used. The best way to repair a damaged tool cord is to have it fixed by a factory authorized service center. Why? Because that maintains the tool’s UL listing (or equivalent). Covering up damage with tape isn’t a fix – electrical tape lacks the same insulating ability and flexibility as the original cord jacket.
Electrical tools need to be UL listed or equivalent. That means that the tool meets safety standards established by a Nationally Recognized Testing Laboratory (NRTL). Underwriters Laboratory (UL) is the best known, but not the only one. FM is another. OSHA certifies NRTLs, recognizing them as qualified to certify the equipment. That requirement leads to a caution: if you want to replace the cord or plug on a certified tool, you might be violating the manufacturer’s instructions. If the tool’s equipment manual says that all repairs need to be made by a factory-authorized service center, then replacing the cord yourself would result in the tool no longer being certified.
Electrical tools have to be grounded or double-insulated. Grounded tools have a three-prong plug. If the tool is double-insulated, its plug will have only two blades, but the tool will be marked as double-insulated or will have a box-within-a-box symbol. Grounded tools help prevent their users from getting shocked – they provide a better path to ground than the human body. Double insulated tools have all electrical parts isolated from the outside non-conductive case. If the wiring shorts, the user won’t be shocked.
Keep guards in place and correctly adjusted. The most common violations we see are on bench grinders. The grinding wheels are usually mounted with the required blotters (compressible washers that go between the wheel and the flanges) and with the guard that goes around 75% of the wheel. But work rests are often dropped down or not adjusted to within 1/8” of the wheel. And it seems that few people know to adjust the tongue guard at the top of the wheel. That has to be within ¼” of the wheel. The work rest keeps the work piece from being sucked into the wheel. The tongue guard protects the user from sparks and from shrapnel if the wheel explodes.
The other common violation we see is lack of guarding on hydraulic shop presses. When a bearing has tons of pressure put on it, it can burst and send fragments out towards the user. People have been killed by that. But these presses usually do not come with guards. That does not let you off the hook. It isn’t difficult to fabricate a guard to protect the user against that ejection of parts.
Follow the manufacturer’s instructions. Have you read the manual for your bench grinder? One of the instructions it will give is to ring test a new wheel before it is installed. To do that, tap the wheel about a half inch from the edge with something nonmetallic. If you hear a dull thud, the wheel is damaged and must not be used. Damaged or incorrectly mounted grinding wheels can explode, sending chunks flying out at speeds above 60 miles per hour. The guards, if correctly adjusted, will help contain the shrapnel. But preventing a wheel from exploding is safer than containing it.
Minnesota explicitly requires you to follow the manufacturer’s instructions. If you want to use a screwdriver as a crowbar and want to comply with OSHA standards, you either need the manufacturer’s written approval or need the okay of someone who can evaluate that use “in accordance with accepted engineering requirements.” Think that’s overreach? In 2017, an employee in St. Paul punctured a car tire with a knife. The tire exploded, sending the knife into the worker’s neck. The worker was injured badly enough to require hospitalization. The company received a $3000 citation for that.
OSHA has very few specific rules for tools. There are a few:
- If you’re going to use compressed air for cleaning, you need to have effective chip guarding, so particles don’t fly at the user. The employee must wear appropriate personal protective equipment. The pressure at the tip of the air blow gun must be less than 30 psi if the gun is put against a solid surface. The purpose: to prevent back pressure buildup (causing the air hose to burst or to fly around) if the nozzle is blocked. Air guns can be designed with pressure relief ports or with solid tips (so the air comes out of multiple orifices just behind the tip).
We’ve seen air guns marked as OSHA compliant only if the airline pressure is 30 psi or less. It’s rare for anyone to reduce the airline pressure that much. Instead, you need to require employees to use air guns that will reduce pressure if deadheaded.
- Pneumatic tools need to have retainers, so the tool won’t come off unexpectedly. The air hose and connectors have to be suitable for the pressure and conditions of use.
- Jacks need to be marked with their load limit. They can’t be overloaded. They must not be raised too high. And once the load has been raised, it needs to be blocked or otherwise secured, so the load is kept raised even if the jack loses pressure.
Jacks need to be inspected for damage at least every six months. If they are damaged, they need to be marked or tagged as out of service and not used until repaired.
Those are straightforward precautions for jacks. Notice, though, that one of the most important parts of using a jack safely, positioning it correctly, isn’t mentioned in OSHA standards. OSHA just doesn’t cover everything.
Misuse of tools can damage the tool, damage what you’re trying to repair, and seriously damage the user. Require your employees to use their tools correctly and to keep them in good condition. That will make their job easier and will keep them safer.
This article originally appeared in AASP News (March 2021). It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or firstname.lastname@example.org.