Machine Guarding for Warehouse and Maintenance Workers

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1. Slide 1

   Machinery Safety

   • What is wrong with this picture?
   • Machine Guarding for Warehouse and Maintenance Workers
   • This material was produced under grant number SH-31178-SH7 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government. Revisions were made to this material under grant number SH-31177-SH7 from the Occupational Safety and Health Administration, U.S. Department of Labor.
2. Slide 2

   Objectives

   • Explain the general requirements for guarding the hazards of machines
   • Describe precautions to be taken around machinery
   • Identify important terms associated with guarding machinery
3. Slide 3

   Machinery Safety 29CFR1910.212

   • Discussion
   • General requirements for machine guards. Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.
   • MVCC Corporate and Community Education
4. Slide 4

   Machinery Safety

   • Machines have the potential to cause
   • Crushed fingers or hands
   • Amputations
   • Burns
   • Blindness
   • MVCC Corporate and Community Education
5. Slide 5

   The Problem

   • Workers who operate and maintain machinery each year suffer approximately
   • 18,000 amputations, lacerations, crushing injuries, and abrasions
   • 800 deaths
   • OSHA 7100
   • MVCC Corporate and Community Education
6. Slide 6

   High-Risk Machinery

   • Mechanical power presses
   • Power press brakes
   • Powered and non-powered conveyors Printing presses
   • Roll-forming and roll-bending machines Shearing machines
   • Food slicers
   • Meat grinders
   • Meat-cutting band saws
   • Drill presses
   • Milling machines
   • Shears, grinders, and slitters
   • Table and portable saws
   • MVCC Corporate and Community Education
7. Slide 7

   The Problem: Machinery Associated with Amputations

   • Mechanical power presses
   • Power press brakes
   • Powered and non-powered conveyors Printing presses
   • Roll-forming and roll-bending machines Shearing machines
   • Food slicers
   • Meat grinders
   • Meat-cutting band saws
   • Drill presses
   • Milling machines
   • Grinding machines
   • MVCC Corporate and Community Education
8. Slide 8

   Causes of Machine Incidents

   • Reaching in to “clear” equipment
   • Not using Lockout/Tagout
   • Unauthorized person doing maintenance or using the machines
   • Missing or loose machine guards
   • Lack of training
9. Slide 9

   Prevention

   • Safeguarding any machine part, function, or process which may cause injury
   • Controlling or eliminating all hazards where the operation of a machine can injure the operator or other workers
   • Training workers on the hazards of machines and how to safely operate and repair machinery
10. Slide 10

    Applicable OSHA Standards

    • 29 CFR Part 1910
    • Subpart J (1910.147): The control of hazardous energy (Lockout/Tagout)
    • Subpart O: Machinery and machine guarding
    • Subpart P (1910.243): Guarding of portable powered tools
    • Subpart R: Special industries (e.g., Bakery equipment)
11. Slide 11

    OSHA Citations Fiscal Year 2016

    • Lockout/Tagout (1910.147)
    • 5th most frequently cited standard
    • Machines, general requirements (1910.212)
    • 8th most frequently cited standard
12. Slide 12

    OSHA Requirements for Recordkeeping and Reporting

    • Employers of 11 or more employees must maintain records of occupational injuries and illnesses
    • All employers must display the OSHA poster
    • All employers must report to OSHA within 8 hours a fatality, any in-patient hospitalization, any amputation, and any loss of an eye within 24 hours
    • These reports maybe made by telephone or in person to the nearest OSHA area office listed at www .osha.gov or toll-free number telephone(800)321- OSHA(6742)
    • Employers maybe subject to other reporting requirements in other OSHA standards as well
13. Slide 13
    • Employers’
    • responsibilities
    • Employers’ responsibilities Under under
    • OSHA
    • OSHA
    • Provide a safe and healthful workplace free of recognized hazards
    • Follow OSHA standards
    • Provide worker training in an understandable language
    • Maintain injury/illness records (Information on the OSHA 300A log)
    • Provide required safety gear
14. Slide 14

    Employees’ rights under OSHA

    • Filing an OSHA complaint
    • Participating in OSHA inspections and talking to an inspector
    • Accessing employer exposure and injury records
    • Reporting an injury
    • Complaining to the employer about a safety and health concern
15. Slide 15

    Whistleblower Laws

    • Section 11(c) of the OSHA Act prohibits employers from discriminating against employees who exercise their rights
    • OSHA also enforces anti-discrimination laws for 22 other statutes
16. Slide 16

    Employer Prohibited Retaliatory

    • Firing or laying off
    • Blacklisting
    • Demoting
    • Denying overtime or promotion Disciplining
    • Denial of benefits
    • Failure to hire or rehire
    • Intimidation and harassment Making threats
    • Reassignment
    • Reducing pay or hours
17. Slide 17

    Complaint Procedures

    • Safety and health complaints should be filed when problem is noticed
    • Whistleblower complaints must be filed within 30 days of alleged reprisal
    • Complaints may be filed online, fax, mail or telephone
    • Complaints are confidential
18. Slide 18

    Machine Guarding

    • OSHA’s 1910 Subpart O
19. Slide 19

    Basic Areas To Be Safeguarded

    • Point of Operation
    • Power Transmission Apparatus
    • Other Moving Parts
20. Slide 20
    • Point
    • of
    • Operation
    • Point of Operation
21. Slide 21

    Power-Transmission

    • Power-Transmission Apparatus
    • Apparatus
    • apparatus (shafting, flywheels, pulleys, belts,
    • chain drives, etc.) less than 7 feet from the floor or working platform must be guarded.
    • Unguarded belt and pulley
    • OSHA
22. Slide 22

    Hazard Identification

    • Motions
    • Actions
    • Rotating (including in-running nip points)
    • Transverse
    • Reciprocating
    • Cutting
    • Punching
    • Shearing
    • Bending
23. Slide 23

    Rotating Motion

    • Hazard
    • Danger – increases
    • Machinery
    • when
    • grips
    • projections
    • and moves
    • are present hair and body parts into clothing,
    • Screws, danger
    • area
    • bolts, nicks, abrasions, etc.
24. Slide 24

    Rotating Parts with Projections

    • BURR
    • Rotating pulley with spokes and projecting burr on face of pulley
    • OSHA 3067
    • Rotating shaft and pulleys with projecting key and set screw
    • Rotating coupling with projecting bolt heads
25. Slide 25

    In-Running Nip Points

    • OSHA 3067
    • Nip Point
    • Nip Point OS
    • Nip Point
    • MVCC Corporate and Community Education
26. Slide 26

    In-Running Nip Points

    • Nip Points
    • OSHA 3067
    • Nip Point
    • Nip Point
27. Slide 27

    Transverse Motion

    • Movement in a straight, continuous line around rotating component
    • Hazard may strike or catch employee a pinch or shear point
    • OSHA3067
28. Slide 28

    Reciprocating Motion

    • Back and forth / up and down
    • Hazard - Caught between moving part and stationary object
    • OSHA 3067
29. Slide 29

    Bending Actions

    • Power applied to slide to draw or stamp metal or other materials in a bending motion
    • Example: Press Brake, Tube Benders
    • OSHA 3067
30. Slide 30

    Bending Actions

    • Press Brake
    • OSHA GI 10 Hour
    • MVCC Corporate and Community Education
31. Slide 31

    Punching Actions

    • Power applied to slide ram for purpose of blanking, drawing or stamping
    • Example: Power press
    • OSHA
32. Slide 32

    Shearing Actions

    • Apply power to slide or knife to trim or cut
    • OSH A3067
33. Slide 33

    Shearing Actions Sheet Metal Shear

    • NJAFL-CIO
    • OSHA 7100
34. Slide 34

    Cutting Actions

    • Rotating, reciprocating or transverse motion
    • Examples: Band saw, circular saws, lathes, drills
    • OSHA 3067
35. Slide 35

    Types of Safeguards

    • Guards
    • Devices
    • Location/distance
    • Automatic/semiautomatic feed or ejection
    • Miscellaneous
36. Slide 36

    Types of Guards

    • Fixed
    • Provide secure barrier
    • Interlocked
    • Cuts off power when guard opened or removed
    • Adjustable
    • Barrier manually moved to accommodate stock or operation
    • Self-adjusting
    • Barrier automatically moves to accommodate operation
37. Slide 37

    Fixed Guards

    • Advantages
    • Maximum protection
    • Variety of applications
    • In-house fabrication
    • Low cost & maintenance
    • Disadvantages
    • Poor visibility
    • Must remove for repairs requiring LOTO
    • OSHA
    • OSHA 3067
    • OSHA3067
38. Slide 38

    Interlocked Guards

    • Switch that when opened stops power
    • Advantage
    • Maximum protection
    • Portion of guard easily removed for access
    • Disadvantage
    • Can be overridden by employee
    • High cost
    • Maintenance required
39. Slide 39

    Adjustable Guards

    • Advantage
    • Flexibility
    • In-house fabrication
    • Disadvantage
    • Not maximum
    • protection
    • Rely on worker to
    • OSHA 3067
    • properly position
    • May prohibit
    • easy Education
    • Bandsaw blade adjustable guard
    • OSHA 3067
40. Slide 40

    Adjustable Guards Bandsaw

    • Barrier may be adjusted for variable operations
    • What are the drawbacks?
    • Bandsaw blade adjustable guard
    • OSHA 10 Hour GI Presentation
41. Slide 41

    Self-adjusting Guards

    • Advantage
    • Employee not involved in positioning
    • Readily available
    • Disadvantage
    • Not maximum protection
    • May need frequent fine tuning
    • OSHA 3067
42. Slide 42

    Self-adjusting Guard Table Circular Saw

    • OSHA GI 10 Hour
43. Slide 43

    Devices

    • Presence sensing • Safety Controls
    • Photoelectrical
    • Radiofrequency
    • Electromechanical
    • Pullback
    • Restraint
    • Safety trip control
    • Two-hand control/trip
    • Gates
44. Slide 44

    Presence-Sensing Device

    • www.osha.gov/SLTC/etools/machineguarding/presses/psd.html
45. Slide 45

    Pullback Device

    • Utilizes a series of cables attached to the operator’s hands, wrists, and/or arms
    • Primarily used on machines with stroking action
    • Allows access to the point of operation when the slide/ram is up
    • Withdraws hands when the slide/ram begins to descend
    • OSHA 10 Hour GI Presentation
46. Slide 46

    Types of Machine Safe Guards

    • Hands in die, feeding
    • Point of operation exposed
    • Pullback device attached and properly adjustedHands in die, feeding
    • Pullback device attached and properly adjusted
    • OSHA 10 Hour GI Presentation
47. Slide 47

    Restraint Device

    • Uses cables or straps attached to the operator’s hands and a fixed point
    • Must be adjusted to let the operator’s hands travel
    • within a predetermined safe area
    • OSHA GI 10 Hour
    • Hand-feeding tools are often necessary if the operation involves placing material into the danger area
    • NJAFL-
    • CIO
48. Slide 48

    Two-Hand Control

    • Requires constant, concurrent pressure to activate the machine
    • The operator’s hands are required to be at a safe location (on control buttons) and at a safe distance from the danger area while the machine completes its closing cycle
    • OSHA GI 10 hour
49. Slide 49

    Safety Tripwire Cables

    • Device located around the perimeter of or near the danger area
    • Operator must be able to reach the cable to stop the machine
    • OSHA GI 10 hour
50. Slide 50

    Gate

    • Movable barrier device which protects the operator at the point of operation before the machine cycle can be started
    • If the gate does not fully close, machine will not function
    • OSHA GI 10 hour
    • Gate Open
    • Gate Closed
51. Slide 51

    Gate

    • Vertical Downstroke Baler
    • www.cdc.gov/niosh/hc14.html
52. Slide 52

    Safeguard by location/distance

    • Position dangerous parts of machine in inaccessible areas
    • during normal operation
    • Moving parts more
    • than 7 feet above floor
    • Controlled access
    • room
    • Control station at safe distance from machine
    • OSHA GI 10 hour
53. Slide 53

    Feeding and Ejection Methods

    • Automatic / semiautomatic feed
    • Automatic / semiautomatic ejection
    • Robots
54. Slide 54

    Automatic Feed

    • (shown on power press)
    • Transparent
    • Enclosure
    • Guard
    • Stock Feed
    • Roll
    • Dang er
    • Area
    • Completed Work
    • OSHA 3170
55. Slide 55

    Robots

    • Machines that load and unload stock, assemble parts, transfer objects, or perform other tasks
    • Best used in high-production processes requiring repeated routines where they prevent other hazards to employees
    • Press
    • Robot
    • Stock
    • Conveyor
    • Fixed Barrier
    • OSHA 3170
56. Slide 56

    Miscellaneous

    • Awareness Barriers
    • Protective Shields
    • Hand tools
57. Slide 57

    Awareness Devices

    • Alert employees to hazard
    • Signs
    • Awareness signals (audible or visual)
    • Awareness barriers (allows access to machine danger areas, but is designed to contact employee, creating an awareness that employee is close to danger point)
58. Slide 58

    Protective Shields

    • These do not give complete protection from machine hazards, but do provide some protection from flying particles, splashing cutting oils, or coolants.
    • OSHA 3067
    • OSHA 3067
59. Slide 59

    Holding Tools

    • Used to place and remove stock in the danger area
    • Not to be used instead of other machine safeguards, but as a supplement
    • OSHA 3067
60. Slide 60

    General Requirements for Safeguards

    • Prevent contact
    • Secure, tamper-resistant, and durable
    • Protect from falling objects
    • Create no new hazards
    • Create no interference
    • Allow safe lubrication and maintenance
61. Slide 61

    General Requirements for Safeguards

    • Fixed guards should be used whenever possible Prevent contact
    • Secure, tamper-resistant, and durable
    • Protect from falling objects
    • Create no new hazards
    • Create no interference
    • Allow safe lubrication and maintenance
62. Slide 62

    Machinery: General Safety Principles

    • Securely fasten equipment to eliminate movement or “walking”
    • No loose clothing, long hair, jewelry, or gloves around rotating machine parts
    • Respect machine guards
    • Keep electrical cords and plugs intact
    • Inspect machinery before each use
63. Slide 63

    Machinery: General Safety Principles

    • Do not leave machines running and
    • unattended
    • Never attend to brush debris from the table surface while the machine is running
    • An active brake mechanism adds greatly to safety
    • Easily reached “off” switch increases safety
64. Slide 64

    Machine Safety Responsibilities

    • Management
    • ensure all machinery is properly guarded
    • Supervisors
    • train employees on specific guard rules in their areas
    • ensure machine guards remain in place and are functional
    • immediately correct machine guard deficiencies
65. Slide 65

    Machine Safety Responsibilities

    • Employees
    • do not remove guards unless machine is locked and tagged
    • report machine guard problems to supervisors immediately
    • do not operate equipment unless guards are in place
66. Slide 66

    Employee Training

    • Hazards associated with particular machines
    • How the safeguards provide protection and the hazards for which they are intended
    • How and why to use the safeguards
    • How and when safeguards can be removed and by whom
    • What to do if a safeguard is damaged, missing, or unable to provide adequate protection
67. Slide 67

    Machine Guarding

    • Checklist
68. Slide 68

    Machine Guarding

    • Case Studies
69. Slide 69

    Control of Hazardous Energy

    • Lockout/Tagout (LOTO)
    • 29 CFR 1910.147
70. Slide 70

    LOTO Purpose

    • To prevent serious injury or death from the unexpected release of stored energy during servicing and maintenance of machines
    • To establish procedures to physically isolate stored energy from the equipment being serviced or repaired
71. Slide 71

    Types of Stored Energy Needing Isolation

    • Electrical
    • Mechanical
    • Hydraulic
    • Pneumatic
    • Chemicals
    • Thermal
    • Other energy sources
72. Slide 72

    LOTO Applies

    • When servicing and maintaining equipment, and unexpected startup of the machine or released of stored energy could occur
    • When, during normal production, workers must remove or bypass a guard or safety device
    • When, during normal production, workers place and part of their body into the danger zone or near the machine’s point of operation
    • During all set up activities
73. Slide 73

    LOTO Exemption Normal Production Operations

    • Routine, repetitive, & integral to production
    • Guards/safety devices not bypassed
    • Body part not placed in the point of operation or other dangerous area during machine cycle
    • Need to use alternative measures for protection
74. Slide 74

    LOTO Exemption

    • Cord & Plug Connected Equipment
    • Plug is only source of energy
    • Plug is under continuous control of one person
    • Cord is unplugged from energy source
75. Slide 75

    Important LOTO Elements

    • Written procedures
    • Documentation of each source of energy
    • Locking and tagging devices
    • Verification of energy isolation
    • Proper locks at proper places (isolation points)
    • Training (including skills demonstration) in the primary language(s) of employees.
    • Auditing of work process
76. Slide 76

    Worker Categories

    • Authorized employee – Person who does LOTO to perform servicing
    • Affected employee – Person required to use machines/equipment on which servicing is performed under LOTO or who must work in such an area
    • Other employees – All employees who are or may be in an area were LOTO may be utilized
77. Slide 77

    LOTO Steps Shutdown

    • Notify affected employees
    • Prepare for LOTO: review LOTO procedures, identify energy sources, confirm LOTO methods to be used and obtain necessary LOTO equipment
    • Shutdown machine following normal procedures
    • De-activate energy isolating devices
78. Slide 78

    LOTO Steps Shutdown

    • Lock out the energy isolating device(s)
    • Dissipate or restrain stored or residual energy
    • Verify machine is disconnected from the energy source(s)
79. Slide 79

    LOTO Steps Startup

    • 1. Inspect machine and surrounding area to ensure machine ready for normal operation
    • 2. Ensure affected employees are away from hazards
    • 3. Remove locks and tags from isolation devices and reenergize machine
    • 4. Notify affected employees of restart and verify machine is working properly
80. Slide 80

    Energy Isolating Devices

    • Device that physically prevents the transmission or release of energy
    • Includes: electrical circuit breakers, disconnect switches, line valves and a blocks
    • Excludes: push buttons and selector switches
81. Slide 81

    LOTO Devices

    • Includes locks, tags, chains, wedges, key blocks, and self-locking fasteners
    • Uniquely identified and used only for controlling energy
    • Durable
    • Standardized
    • Substantial
    • Identify employee applying device
    • Tags must have special warnings
82. Slide 82

    Training

    • All employees must be trained based on worker categories
    • Must ensure employees understand LOTO program
    • Must address limitations of tags if they are used as part of LOTO
83. Slide 83

    Retraining

    • Authorized/Affected Employees: when change in job, change in machines and change in LOTO program
    • When evidence indicates employees lack knowledge of LOTO program
84. Slide 84

    Some Examples of Machine

    • Guarding
85. Slide 85

    Unguarded Fan Blade

86. Slide 86

    Guarding Fan Blades

    • Guard when periphery of blades is less than 7’ above the floor or working level
    • Guards with openings no larger than ½”
    • Source: OSHA
    • OSHA 3067
87. Slide 87

    Abrasive Wheel Machinery

    • Improper Work Rest and Tongue
    • OSHA 3067
88. Slide 88

    Abrasive Wheel Machinery

    • Work rests on offhand grinding machines must be kept adjusted closely to the wheel with a maximum opening of 1/8-inch to prevent the work from being jammed between the wheel and the rest, which may result in wheel breakage.
    • OSHA 3067
89. Slide 89

    Abrasive Wheel Machinery

    • The distance between the wheel periphery and the adjustable tongue must never exceed 1/4-inch.
    • OSHA GI 10 hour
90. Slide 90

    Abrasive Wheel Machinery

    • When installing new abrasive wheel
    • Inspect for condition and compatibility
    • Conduct ring test
    • OSHA 7100
91. Slide 91

    Abrasive Wheel Machinery

    • Checklist
92. Slide 92

    Bench Grinder Explodes

    • https://youtu.be/2ou6HSwj-IU
93. Slide 93

    Portable Circular Saws

    • OSHA 3067
    • Guard Retracted
    • Stock
    • Blade
94. Slide 94

    Table Saw

    • Guard
    • www.osha.gov/SLTC/etools/machineguarding/saws/tablesaws.html
    • On/off switch should be located at knee height -- so you can turn off machine while your hands are on the material
    • Blade must be guarded
    • Automatic brake a good safety feature
95. Slide 95

    Table Saw -- Kickback

    • Back of the blade, as it rises out of table, is the critical “kickback zone”
    • Material tends to be lifted off of the table
    • If wood moves sideways at this point, it will be caught by the rotational motion and will be flung back toward the operator!
96. Slide 96

    Preventing Kickbacks

    • Use a splitter or wedge inserted into the saw kerf to separate material
    • Make sure rip fence is perfectly parallel to the blade
97. Slide 97

    Table Saw - Splitters

    • Metal fins, secured behind and in line with the blade -- must move freely & not stick open
    • Anti-kickback pawls also attached
    • www.osha.org/pdf/pubs/2980.pdf
    • Splitter & anti-kickback pawls
98. Slide 98

    Table Saw - Push Sticks

    • NJAFL-CIO
99. Slide 99

    Radial Arm Saw

    • www.osha.gov/SLTC/etools/machineguarding/saws/tablesaws.html
    • Anti-
    • Kickback
    • Device
    • MVCC Corporate and Community Education
    • Lower Blade Guard
100. Slide 100

     Meat Cutting Band Saw

     • OSHA 3170
     • OSHA 3170
101. Slide 101

     Meat Cutting Band Saw

     • Follow LOTO Procedures
     • Install Brake
     • Use Push Guard or Fence
     • Adjust Blade Guard
     • Use Only Sharp Blades
     • Only Remove Meat When Blade Stopped
     • Unplug When Not In Use
102. Slide 102

     Jointer

     • Large, high-speed cutterheads are main hazard
     • Knives rotating at high speed become invisible
     • OSHA 3170
103. Slide 103

     Jointer

     • Do not pass material over planing head by hand
     • – Only one layer of material between your hands and the cutters
     • Keep guards in place -- open cover only enough to allow material to pass through
104. Slide 104

     Jointer

     • OSHA 3170
105. Slide 105

     Food Slicer

     • Case History: an employee was cleaning a meat slicer that was turned off but was still plugged in. He inadvertently turned the machine on by bumping the on/off switch, resulting in an amputation of his right ring fingers.
106. Slide 106

     Food Slicers

     • 1. Never hand-feed slicer
     • 2. Retract the slicer blade during cleaning
     • 3. Unplug when servicing or use lockout/tagout
     • OSHA
107. Slide 107

     Meat Grinder

     • Use properly sized plungers
     • Operate with feeding tray and throats installed
     • Follow LOTO procedures
108. Slide 108

     Machinery: General Safety Principles

     • Securely fasten equipment to eliminate movement or “walking”
     • No loose clothing, long hair, jewelry, or gloves around rotating machine parts
     • Respect machine guards
     • Keep electrical cords and plugs intact
     • Inspect machinery before each use
109. Slide 109

     Machinery: General Safety Principles

     • Do not leave machines running and unattended
     • Never attend to brush debris from the table surface while the machine is running
     • An active brake mechanism adds greatly to safety
     • Easily reached “off” switch increases safety
110. Slide 110

     Quiz

111. Slide 111

     Meat Grinder

     • Use proper size plungers
     • Operate with feeding tray and throats installed
     • Follow LOTO procedures
     • OSHA 3170
112. Slide 112

     Meat Grinder

     • Use properly sized plungers
     • Operate with feeding tray and throats installed Follow LOTO procedures
     • OSHA 3170
113. Slide 113

     Resources

     • OSHA Machine Guarding Website
     • http://www.osha.gov/SLTC/machineguarding/index.html
     • OSHA Machine Guarding eTool
     • http://www.osha.gov/SLTC/etools/machineguarding/index.html
     • OSHA Amputation Fact Sheet
     • http://www.osha.gov/OshDoc/data_General_Facts/amputation-factsheet.pdf
     • Safeguarding Equipment and Protecting Employees from Amputations
     • http://www.osha.gov/Publications/osha3170.pdf
     • MVCC Corporate and Community Education
114. Slide 114

     Resources LOTO

     • Resources LOTO
     • OSHA LOTO Website https://www.osha.gov/SLTC/controlhazardousenergy/index.html
     • NIOSH Workplace Solutions: Using Lockout and Tagout Procedures to Prevent Injury and Death during Machine Maintenance https://www.cdc.gov/niosh/docs/wp-solutions/2011- 1 56/pdfs/2011-156.pdf
     • OSHA LOTO Fact Sheet https://www.osha.gov/OshDoc/data_General_Facts/factsheet- lock out-tagout.pdf
     • OSHA 3120: LOTO https://www.osha.gov/Publications/osha3120.pdf