Practical safeguards

PUWER requires that access to dangerous parts of machinery should be prevented in a preferred order or hierarchy of control methods. The standard required is a practicable one, so that the only acceptable reason for non-compliance is that there is no technical solution. Cost is not a factor. (See Chapter 1 for more details on standards of compliance.) 

Since the mechanical hazard of machinery arises principally from someone coming into contact or entanglement with dangerous components, risk reduction is based on preventing this contact occurring. 

The best method should, ideally, be chosen by the designer as early in the life of the machine as possible. It is often found that safeguards which are bolted on instead of built in are not only less effective in reducing risk, but are also more likely to inhibit the normal operation of the machine. In addition, they may in themselves create hazards and are likely to be difficult and hence expensive to maintain. 

Fixed guards have the advantage of being simple, always in position, difficult to remove and almost maintenance free. Their disadvantage is that they do not always properly prevent access, they are often left off by maintenance staff and can create difficulties for the operation of the machine. 

These are fixed or moveable guards, which are adjustable for a particular operation during which they remain fixed. They are particularly used with machine tools where some access to the dangerous part is required (e.g. drills, circular saws, milling machines) and where the clearance required will vary (e.g. with the size of the cutter in use on a horizontal milling machine or with the size of the timber being sawn on a circular saw bench). 

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The purpose of NFPA 70 is to provide a guide for the practical safeguarding of persons and property from hazards arising from the use of electricity. It covers installation of electrical conductors within... 

This subpart addresses electrical safety requirements that are necessary for the practical safeguarding of employees involved in construction work and is divided into four major divisions and applicable definitions as follows ... 

Members shall in their professional practice safeguard public health and safety and have regard to the protection of the enviromnent... 

Employers must, as far as is reasonably practicable, safeguard the health, safety and welfare of employees (section 2). In particular, this extends to the provision and maintaining of ... 

Residual monomers exhibit a characteristic sharp odor even in subtoxic concentration, due to the very low olfactory threshold. Modem requirements in terms of environmental safeguard have led to significant improvements in the control of polymerization effluents, driving off gases, and residual monomer in the raw polymer. Consequendy, the acryUc elastomers of the 1990s are practically odor-free, and represent a significant improvement over the products of the past. 

Recommended Good Practice for Safeguarding Flammable Liquids, Factory Insurance Assoc., Hartford, Conn. 

It is the duty of employers, as far as is reasonably practicable, to safeguard the health, safety and welfare of the people who work for them and others who may be affected. This applies in particular to the provision and maintenance of safe plant and equipment and methods of work, and covers all plant, equipment and substances used. Specific areas that require attention include ... 

Table 15.13. This specification follows good industrial practice, with additional safeguards in rinsing to remove residues to treatment solutions. Nonaccelerated treatments must be followed by a single rinse which may contain chromate accelerated treatments must be followed by three rinses—cold water, hot water and a final chromate rinse. Table 15.14 shows the salt-spray test requirements for phosphate coatings with various finishes without formation of rust the paints and lacquer have the additional requirement that no rust shall be visible beyond 0-2 in (5 mm) from the deliberate scratches and no blistering, lifting or flaking beyond 0-05 in (1-27 mm) from the original boundaries of the scratches.

As an additional safeguard, it is common practice to use an appropriate polymeric sludge conditioner, which will maintain precipitates in suspension for removal with the BD. 

Maintenance embraces regular inspection, periodic examination by competent persons , and repairs. All maintenance on equipment used with chemicals should be properly planned and recorded. Maintenance operations, particularly those which are non-routine, require a sound system of work with strict administrative procedures, e.g. permit-to-work, to avoid risks arising from modifications to established safe practices. A permit-to-work should be used wherever the method by which a job is done is likely to be critical to the safety of the workers involved, nearby workers, or the public it is required whenever the safeguards provided in normal operations are no longer available. Examples include ... 

The safe operation of such processes depends on the design and provision of engineered safety devices, and on good operating practices, to prevent a dangerous situation developing, and to minimise the consequences of any incident that arises from the failure of these safeguards. 

The fact that spent fuel reprocessing and recycle are essential components ofgood nuclear non-proliferation and radioactive waste management practices. These actions are needed so that more efficient use can be made offissionablc materials, and unwanted radioactive fission products can be disposed of without need for permanent safeguards. In addition, potential weapons usable materials are destroyed through beneficial use. 

In most instances, the safeguarding inherent in the facility (the piping, the plant layout, and its operating practices) is sufficient without need for additional safeguarding. In some instances, however, engineered safeguards must be provided. 

Section 271 of S.2255 would provide some small measure of protection to manufacturers when their process which is patented in this country is practiced outside of the country, presumably by cheaper labor, with the goods then imported to the detriment of the U.S. manufacturer and to labor paid on U.S. standards. However, this provision takes effect only if the importer is the exclusive or primary distributor. If there are several non-exclusive distributors—none being primary —this safeguard would not apply. This entire provision thus would be easy to avoid. There are important issues here involving labor policy and international trade as well as patent law and fairness. Any change in the law should consider all the issues. 

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