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Scope: Petition 580 recommends revisions to Cal/OSHA’s existing anti-restart & machine guarding regulations. These changes have the potential to impact every machine in California. While this particular update is directed at Cal/OSHA, the regulations it cites also exist in Fed/OSHA regulations.
Item #1: Cal/OSHA has existing requirements for the prevention of unintentional restarts after restoration of power (Title 8 §2530.43) but the requirements are buried in the electrical safety orders and often go unnoticed by safety professionals when consulting their respective machine guarding sections. Petition 580 seeks to reference these regulations from the machine guarding section (Title 8 §4001) and to better define the language around anti-restart & machine guarding requirements. This will clarify the intent of the standard and make it easier for business to comply with these requirements.
Item #2: Cal/OSHA has existing requirements that all electric equipment be listed by a Nationally Recognized Test Lab (NRTL). This petition illustrates examples of how misleading products are currently in the market and seeks to remedy the error in order to:
- Reduce risk of electrical fire: excessive starting currents and inductive arcing on under-rated switching devices can lead to overheating, smoldering, and fire.
- Reduce failures of engineering controls: examples show how some devices are installed as safety controls yet excessive starting currents and inductive arcing can lead to contacts permanently welding into the closed (“ON”) position – thereby completely negating the safety function.
- Educate companies who often fall victim to deceptive marketing.
- Prevent additional workplace hazards caused by ineffective safety mechanisms.
A full transcript of the webinar is available below for those that prefer to read. Links and resources are available at the top of this page, including the full text of the petition and the video recording of the live webinar that details unintentional restarts and the details surrounding this petition.
Webinar Transcript:
(this is a live webinar transcript, please forgive any mistakes in transcription)
Introduction
Good morning, everyone. My name is Laura Bolt and I’ll be your emcee for today. We’re really glad to see you all here this morning. Today we’re sponsored by MAKESafe Tools and the San Diego Chapter of ASSP! We are so glad to see you all here this morning. Today our speaker is going to be Mr. Scott Swaaley. He is the founder and president of MAKESafe Tools. He is an accomplished carpenter, machinist, hobbyist, programmer, and practicing engineer. He’s been featured in a number of documentary films, he holds a US patent, and of course like the rest of us he is a big dog person with his lovely greyhounds. He has over a decade of experience with electrical design for hospitals, data centers, and renewable energy systems, and is also an active participant in the regulatory processes with NFPA, OSHPD, RTLs, and Cal OSHA, which is why we are here today. So without further ado, I’m going to hand things over to him and we can get started. Thank you all for joining us. I look forward to answering your questions.
Webinar
Awesome. Thank you very much, Laura. We are going to get rolling. Thank you to everyone from ASSP that has joined as well as the rest of our attendees – were already up at 54. That’s great for an early morning webinar. Starting off: Why are we talking about this? I think this is an important place to start. Why I’m passionate about this particular topic and there’s two real reasons. One is something that we hear a fair amount: that injuries happen a lot. But I’ve spent weeks and weeks digging through the data of how injuries happen, when injuries happen, reading incident reports. The few things that jumped out at me are:
One, that there’s about 40,000 people a year that suffer from traumatic machine related injuries, if we really target down for that one injury type. It’s been the same year after year, after year. When I started seeing that I started asking questions and wondering “Why is that the case?”
Then, of course, we see when OSHA releases their most common citations reports, which they have been doing since 2002 every single year, machine guarding is on it. Early on, when I when I came into this industry that frustrated me a lot, because I would see there is no change in injury rates, and when it gets to the actual thing that we know will prevent these injuries, people still aren’t doing them.
I’ve transitioned that frustration over the years into really trying to get down to why that is. One of the reasons I found is this simple answer: machine guarding is really hard! Doing it right is even harder. What my company is about, and what this webinar is about is about making a few really simple, actionable things we can pull out of that – and you’ll see how this petition ties into that. Then secondly, we like to think on a day to day basis that like, our intent is enough. Sometimes it feels like those details don’t matter, but then there’s sometimes that they really do.
I’m gonna do a little thought experiment for a second before we roll into it. Imagine for a minute that let’s say we have a loved one, a parent that’s older, taking some new medications. Let’s say it’s your mother, and she’s being helped with a prescription drug to help heart disease. Let’s say, a few weeks into that process, there are some side effects you didn’t expect. In talking to a doctor, you find out that, Oh, well, that medication that was prescribed actually isn’t for heart disease. It’s something that’s for another disease, but they thought it might work for that, so they wanted to try it. If you imagine that might be a little frustrating, right? As a consumer, you’d expect that between the FDA and a doctor that they’re making informed choices about your health. Let’s take it one step further and what if you then found out that medication was approved for another purpose? It not only isn’t for heart disease, but on the label says: “Not for people over 50 and not for use with heart disease.” So imagine that for a sec, that something that was about your health and the health of a loved one was specifically not allowed to be used for that, but that a regulating agency and maybe a doctor had prescribed it. That would be really frustrating.
What we’re going to find out as we go through this webinar is that in the safety industry, there are things like that happening right now, where even a very well intentioned and informed safety professional can make what seemed like very reasonable choices, and actually end up with devices that fail and cause other hazards. So we’re going to be digging into that as part of the petition. So hopefully, that connects and we’ll move forward.
We also are going to be talking about a lot of different topics, but funneling it down to one. I mentioned earlier that one of my frustrations that machine guarding is just so nebulous and large. So, we will tangentially mention a lot of different things. We’ll talk a little bit about ANSI, a little bit about hazardous energy control, a little bit about state versus fed OSHA. But in the end, the thing that we’re really going to focus on today is one part of accidental restarts, because it’s actionable, it’s inexpensive, and it’s something that we can all do quite literally today in our facilities.
For people that are from out of state know that even though we’re talking about a California petition today, all of these concepts apply federally. Then, as I mentioned, we’re also going to be looking specifically at electrical and electrical motor type things. Obviously, hazardous energy and things like that also include pneumatics, gravitational, hydraulic, and lots of other energies. We’re not going to be focusing on those today.
So, what is this petition, Petition 580. I’d be curious to hear if anyone read the petition in advance. If you did, please do chat. I’d love to hear what you’ve learned so far, but there’s two parts of Petition 580.
One is to clarify existing regulation, for preventing the unintentional restart of machinery. I say clarify existing because these rules already apply federally, and they already apply in California. The problem is these standards are buried in an area nobody would look. In this specific example, you have a section of machine guarding in Title 8 for Cal OSHA and it has everything that you would expect to find in a machine guarding section. Then, separately, way over in the electrical section, where an electrician might be looking for doing an installation, they have some kind of subtle language about the unintentional restart of machinery. Now as a safety professional, I’m not going to probably be reading all of title eight cover to cover, I’m going to go through the part that I think is relevant to what I’m doing which would be machine guarding. And it is not mentioned in there at all. This petition seeks to remedy that, so people are aware of what really is already a regulation but it’s so easy to miss.
Secondly, is to really dive into those approved but hazardous safety devices that are currently on the market – with that health metaphor I I used a little bit ago.
As we dive in a few just things to know. One, when we say NRTL: an NRTL is a Nationally Recognized Test Lab, like UL (Underwriters Laboratory) – there’s a lot like them. All equipment that basically plugs into the wall in a workplace is required to be approved by a nationally recognized test lab for that particular use. That’s Fed OSHA, that’s Cal OSHA, that’s all of them. So that’s something to keep in mind. Also, that OSHA is actually the regulating body of nationally recognized test labs. That’s a part that a lot of people don’t know OSHA is the one that is inspecting and “certifying” that the nationally recognized test labs are doing what they do. That’s why this all ties together. We’ll get into that as we go through.
So, we’re going to start broad, right, with the world of unexpected startups, like I mentioned, and we’re going to focus down. Starting broad, we’re going to say what do we mean unexpected startups, right, like, what does that mean? Starting with, you think about a piece of machinery that is starting up in a time that is unexpected, and also is likely to cause some kind of energy or even just to prevent it present a hazard. There’s obvious conditions on when a machine restarting would be a hazard. It’s like somebody has their arm in a machine doing maintenance. Or someone is, let’s say, grabbing a workpiece. Or it’s very close to the point of operation. But there’s also some more subtle things, for example, that if a piece of debris or a workpiece, or a jacket is sitting on a machine when it starts, if no one’s ever seen that on a table saw, it basically turns a new catapult. Thinking about like, all these bad things that can happen when things restart.
Now, I remember the time at airports before there were alarms for the baggage carousels. I remember as a kid, very specifically, that I was playing on the carousel when it started, and it scared me to death. I remember I had my sweater around my waist and one of the drawstrings got caught between the two little slats. It only happened for about half a second – it pulled out right away, I was fine – but it scared me to death. Of course, now they have big alarms and lights that go off before that carousel starts moving, because it’s such an obvious hazard. But when we think about most of our equipment, actually, there are a lot of ways it can restart itself. And going over to the left there on the causes. One is just straight up, you accidentally press a button or you have an unprotected footswitch. Right, the actual person using the machine makes a mistake and turns it on by accident, or they reset it when they would not expect it to restart. One good example is that in an emergency stop situation. One of the ANSI requirements is that when you reset an emergency stop, that a separate and intentional action is required to to start the machine after a reset.
As we’re going through through that, the other way is that there’s someone else is turning the machine on, whether they’re aware of the person in that room or not. And when we think about that, that’s often someone in a breaker room. For example, let’s say you trip a circuit breaker and the person in the in the breaker room will go ahead and flip that breaker on, not knowing that someone downstream is using a machine. Other kinds of things that would make a machine start up is if there is a thermal protection device that resets automatically. For example, a lot of lower end motors have a thermal device in them that is very similar to that thing you stick in your turkey. It’s Thanksgiving time, you get that little thermal device that pops out at a certain temperature. A lot of lower end motors will have a device like that, but unlike your turkey when the temperature then drops that will reset. In the event that you have not planned for that near machine guarding, power would be restored to the motor. This is just one of those many things that can come up and be a problem.
I see something from the chat… Doug is saying that he would actually disagree with the manual reset of emergency stop, because emergency stop function only permits restarting, it doesn’t cause a restart. To Doug’s question, absolutely true. And what I’m trying to show by this slide is that there’s just this world of ways the machine can restart. But if you designed machine guarding right, it won’t, which we’re going to get into in just a sec. Doug, I think we’re on the same page, and I’ll get there in just a moment.
The other thing that we’re gonna be talking about specifically today is when we’re thinking about restarting after a loss of power. That basically means: Imagine you’ve got your machine it is in the on position. You lose power for some reason. When power is restored, that is still in the on position, and it will start. Now you would assume that most tools would be designed to not do that, when in fact, almost all of them are. We’re going to be diving into a little bit of what Doug mentioned, now. Almost there. So, also, when we’re talking about machinery, we do literally mean all machinery. Again, we’re talking specifically about electrical today, and specifically about motors, which is a subset of the kinds of restart. But we can obviously think about power tools and machine tools, but also conveyors, rollers, mixing equipment, really anything that has an electric motor. That really expands this scope tremendously. You think that like this is everything that has a motor. There is clarification in the regulation that says: if the restart is likely to cause a hazard or if the restart could be hazardous. When we’re thinking about this, and you look at that mixer, for example, and in the center of the frame, I would argue that no matter what, that starting unexpectedly would be hazardous. Now, if you have a fully enclosed device that uses a motor, and there’s no way for someone to get in there and get hurt, you could very reasonably argue and hopefully document with a risk assessment, that there isn’t a hazard from that restarting, in which case this wouldn’t be required. But as you really have to be able to put your foot down and document that you’ve done that thinking.
Now: diving into what Doug was mentioning. I talked about all those different ways and machine could restart, all the ways that it might. Now there are lots of regulations that control most of those, and the thing that gets hard for people is that they all overlap, and those overlaps aren’t always obvious.
On the right here in this green area is when you’re doing some kind of intentional maintenance. You’re servicing a machine. This is your lockout tagout territory. A huge part of hazardous energy control is making sure that hazardous energy like a restart doesn’t happen when you are indisposed, when you have bypass guards, or when you’re maintaining equipment. Hazardous energy control and these various standards govern and protect people here. This is all lockout tagout territory. We’re not diving into that today, but that is where that should be. On the other hand, as Doug was mentioning, isnormal machine guarding requirements. This is where things exist, like when you reset in E-Stop, the machine should not restart without an intentional and deliberate action. If you’re following existing machine guarding regulations, that’s already covered. Again, that can be a whole webinar in and of itself. Doug, I hope that gets to your question.
Then there’s this middle area. This middle area is a little bit of what we’re talking about today. There’s intentional production, there’s intentional maintenance, there’s also this strange little minor servicing exception that is its own webinar that we could talk about it another time. In these unplanned things the Murphy’s law when things are happening, that we didn’t plan for, whether it’s straight up human error, whether it’s a defect in the material that you hit, there’s a nail you didn’t expect in a piece of raw material, or that there is an under voltage event from the utility, all these different things. And this is where we’re going to focus.
Some of these are pretty clearly covered by machine guarding. Some of them should theoretically be installed by the people physically installing electrical infrastructure, because you can see when we get into this under voltage, loss of power stuff, which is our focus today. Yes, it’s under machine guarding. But it’s often overlooked. It is regulated by nationally recognized test labs, where they regulate the equipment you would use. And the different electrical codes also require that to happen. The problem is: as I go was mentioned earlier with the with how Cal OSHA is currently written, all these things are not mentioned in the machine guarding standards. They’re mentioned in the electrical standards. And that, for me, makes it very unclear because as I mentioned earlier, safety professionals are going to read the machine guarding sections, they’re not going to be digging through all of that. Risk Control in the chat asked a question they said Where would removing a jam be in the schematic? In this schematic which is one of our creations, removing a jam.
This is where it gets gray. Some would argue that would be if a jam was, quote, routine, repetitive and integral to your process. Someone could argue that’s part of your minor servicing exception in normal production, in which case your machine guarding would theoretically protect you. However, if you had to bypass a guard to do this, a case could be made that is then service and maintenance, in which case you need to do lockout and tagout so that it gets very gray. Doug is offering right now in the chat that the over and under voltage requirements are in the NFA 79. Yeah, so if you look on the bottom here, and electrical fire and safety, we do call out NFA 79 is a part of that. Definitely used by control systems engineers.
Where we’re going to be living today is in the area where if you have a large control system that was intentionally designed by a control systems company, all the things we’re talking about are things we’ll be focusing on today is the things where you’re using equipment that doesn’t have that and what you’re You’re in this spot where you might have a piece of equipment that turns on and off, like so many of us do. When I walk into the facility, there is the large equipment with industrial controls. And we’ll be talking through all those things.
But then there’s also the little bands on the corner and the conveyor that only gets used at Christmas, and all these other things that don’t have large elaborate controls. What we’ll be talking about today is not the perfect thing that could cover everything but some low hanging fruit you could do that will help out and could prevent injuries.
So, as I mentioned, we’re really focusing down to these like after loss and restoration of power events. This is not the catch all of all machine guarding. It’s specifically focusing on how, when there’s a loss of and then restoration of power, like in a circuit breaker trip or a brownout, that we machines don’t restart, and you’ll hear this referred to A lot of different things.
One is safe start some people brand that and they will use that to refer to this. You will call it accidental restart prevention protection. My favorite is anti automatic restart protection, which I don’t even know what that means. And then also low voltage dropout. So, low voltage drop out is a similar thing, but it’s sometimes used as a catch all. And then lastly, magnetic switches. Something else: sometimes they have safety switch or magnetic switch when they’re referring to unexpected restarts.
The question is, how do you know if you need this? We’re going to start with just a simple test you can do after the call today. Again, this is only checking for the one subcategory of restart we’re talking about. We’re talking about low hanging fruit, not the perfect solution for everything. if you have a piece of motor driven machinery, whether it’s a conveyor, or a press or a bandsaw, or a mixer, if it’s starting unexpectedly, could injure someone, then you should go through these three steps.
You would go in, obviously, you would clear the space, make sure that people are aware that you’re running a test. So, no one’s going to get hurt, you will literally just turn your machine on, let it come up to speed, let it do what it does, well, it is still in the on position, you will remove power. Now there needs to be a way for you to safely do this. Of course, now you can unplug it, or you can turn it off at a local disconnect. This isn’t something you would want to do everyday. But for this test, it’s reasonable. While that machine is on and running and unloaded, you would unplug it or turn it off at a disconnect counter about to plug it back in. See if that machine restarts. Literally, that should take 10 seconds and when you plug it back in or restore power If that machine turns back on, you do not have restart protection. That’s a very easy test you can do, it will give you just a high level like, Oh, I guess that would be kind of bad, right? When you’re thinking about what machinery to do this on, there are a few quick reminders and some misconceptions that I often see.
One is that inexpensive tools have inexpensive hazards. People assume that there’s this relationship between the cost of a piece of machinery and how dangerous it is. If you have a large CNC system that you can climb into, people are very aware of how hazardous that could be and a lot of time and then tension and money is put into elaborate control systems to protect people. But then someone says, oh, here’s a chop saw that we got for $90 at Harbor Freight that has no protection at all. But because it’s inexpensive, we think that is somehow less of a risk. I would argue that if anything that’s backwards. To really be thinking about when we say machinery, all machinery, because the amputation caused by a $90 saw is the same as an amputation caused by a $10 million CNC machine. Really thinking about what those machines are, and then also not expecting that a new machine complies.
It is not the manufacturer of the machines responsibility to meet OSHA regulations, that is not their job legally, it is the job of the employer. When you buy a piece of equipment, it may have some of these features or it may not, depending on the manufacturer. For example, if you’re buying something like a staple – a piece of woodworking or metalworking equipment – there is kind of an imaginary line around between 1000 and $2,000. Above that, and they tend to include magnetic magnetic switches under that, and they tend not to. Again, rule of thumb, but you will see these bifurcations, where sometimes they’re people, these machines are safe, sometimes they’re not. And the even more terrible part is the magnetic switches themselves are made by the exact same manufacturer, as the non magnetic switches, a Chinese company that makes almost every power tool switch used commercially. When we’re thinking about that they look identical and unless you do this test, or you take it apart and look at model numbers, you don’t know. Really thinking all machinery here. Then last minute before we move on from this is, well, you’re doing this all we’re checking is rest, restart after restoration of power for an electric motor.
And though we’re not focusing on it, it’s a good time to also be looking for other kinds of hazardous energies. When you’re looking at this machine, if there is another motive force, assume there’s something else there. If you see an air hose going to it, assume that there could be some kind of pneumatic energy driven hazard. If there are hydraulics going to it. If there is something heavy, being sustained at a height, assume that gravity could pull that back down, right?
So, just keep an eye out when you do these kind of things, for other hazards, and that when you see something like that, you’re right away, like, Ooh, this is something I should actually do a full risk assessment on, right? You should always do a full risk assessment. But I know in reality, that doesn’t always happen. But when you start seeing those complications, that’s where this little 123 is no longer applicable. Now let’s say you’ve evaluated and have machines that don’t meet this requirement, I should go ahead and buy some equipment to make this better. Now we’re going to dive into a specific customer story. So, and this started my passionate journey down the throat. I have a customer that’s an aerospace parts manufacturer. And they have grinders at every CNC operator station. And they use them for tool sharpening. And I was surprised that they’re still probably using high speed steel instead of carbide for those, but whatever, right?
They have about 70 stations, they have about 70 grinders, these are little guys little like half horse, three quarter horse grinders. And they realized that they needed some anti restart protection. They did everything reasonably. They googled it, they found something that looked like it would work. They bought it, installed them, and it’s great. Now they did something that really helped them here. They, as part of their policy, regularly test all safety equipment. Think about that, that is something that you could very easily argue as part of regulation you should always evaluate your the performance of your safety equipment after mitigation. And then at some regular interval, anything from a monthly test to a every shift test, depending on the mitigation. But they did this monthly, and what they found is that for their 70, brand new anti restart devices, every single month, between one and three would fail. Just to visualize that, what that looks like I’m gonna do a little animation on the screen. Every month, the restart prevention was failing, the brand new ones, on all these machines.
Now one of the things about this is true for most restart from product is they fail silently. Some they can combust and fail gloriously. But often, they will fail without any kind of alarm you won’t even know. This customer was smart enough that they’re testing them regularly. They found this. And this blew my mind is like, “How could something be on the market that has a fail rate that a year after its installed, this many devices are now hazardous again?” That blew my mind. I started digging into it and like any good engineer took one apart. You’ll see I tried to specifically not to call out any manufacturers here because I want you guys to be able to do your own informed research, and I don’t want to go down that road. But know that if you can recognize it, this is one of many This is not the only one. When we’re going through and taking this apart. One of the things that’s surprised me was I had a very small relay in it and the relay is this little black box and this little black box is the main switching component.
And if you’re sizing something for switching a motor and you have some electrical familiarity, there might be a few things you look for. One might be is this switching device approved by a nationally recognized Test Lab. And in this particular case, the device itself is listed by a by ul and this switching device inside it is listed by UL, CSA and TUV. It is a listed product which means that it has been reviewed for electrical and fire safety by a nationally recognized Test Lab. Next thing you might say is it has the correct voltage rating and I’m using this example of a little grinder over here. This particular relay, we’re reading top of it, it’s rated for 125 volts. “Oh look, our grinder’s 125 volts, that should work.” Seems fine. And we see Oh, our grinder only uses eight amps. Oh, this thing’s rated for 15 amps, we should have plenty of margin. If you are a very well intentioned safety professional, you’d be looking probably not at the actual relay inside, but at the product specs. And you would say a 15 amp rated, this should work for my grinder. This is where it gets a little weird.
We obviously know that these were failing already at a huge rate. We have to understand a little bit about electrically what’s happening. Does anyone remember doing that experiment and when you were younger with the nail on the battery, like on the right there make a little electromagnet. So, motors are basically just big electromagnets. They’re they’re they’re what’s called an inductive Load, induction being a way that you can store energy in a magnetic field. Now, anyone also remember when you were making this little thing when you’re in fifth grade, what happened when you connected and disconnected it? You may remember there’s little tiny little sparks. And that is stored energy being stored in a magnetic field trying to discharge itself. When you’re switching motors, specifically motors, they are a notoriously difficult load to switch. Because any actual switch just like shown on the left here is two pieces of metal but touch each other. That’s what most switches are when you get back to their most basic point, but a motor every time you disconnect, it does this. So you see that welding arc flash. A reasonably loaded motor will do that every time you disconnect. You can imagine that would be a very destructive thing for switches. You have to have switching devices or relays that are made for motor use. And this is why this thing fails. Because that tiny little relay that’s not rated for motors, and we’re gonna pause you’re like, wait, wait, wait, I thought this thing was approved by ul it is, but it’s approved as a quote unquote, appliance control. If you look at the actual ul standard that this thing is approved under Ul 246, a, it covers things like household appliances, lights, audio video equipment, not intended for controlling motor operated appliances.
So this is not only not meant for industrial, it’s not even meant for your blender yet their marketing material is right next to big pictures of table saws and drill presses and Mills. And it’d be very easy for someone to fall into that trap versus, for example, ul five away, which is one of the industrial control equipment standards, which historically it’s changing a little bit now. It’s specifically designed for the control of motors in an industrial environment. So just as a quick comparison, these two relays Shown here are to scale and have similar ratings. So those would both be good for a up to a 15 amp motor. The one on the left is obviously tiny and not made to handle those arcs and sparks we showed where the one on the right is and it can handle that because it’s been tested to a much, much higher standard. So again, it’s one of those things where like you wouldn’t know unless you were crazy like me and dig through standards all day. The way though that lesson from this is when you’re looking for things when you’re shopping for products, whether it’s an industrial motor control, or an emergency stop switch to really look to see, is it recognized by a test lab? Or is it listed by a test lab? And is it listed for that purpose? So that’s a big, big distinction. So is it listed for that purpose?
Now, Doug mentioned that this G7L relay is has a lot of features built into it as part of that motor requirement, which makes it able to extinguish those arcs. And part of it is that it actually has a double contact. So instead of one piece of metal separating, there’s two. It shares the load. Also it has these different ways that arc can travel that make it basically go away? From the context faster, lots of things and that are built into this not too different from a circuit breaker that make it safer for motors. And the way to know that I apparently don’t have that slide up here is that it’ll actually say HP horsepower rating on it. It’ll say this is rated for a one horsepower load. So what should you do? You’re in this space, you want to do accidental restart, but you don’t know what to buy. I’m going to give kind of a rough graph of what some of your options are. We have some things down here that I’ve talked about that I wouldn’t recommend, for the reasons we just discussed. But there is still a very inexpensive option
If you have a straightforward piece of equipment and you have the capacity And the expertise to do some simple wiring just to replace a switch, a $20 switch, that is Ul 508 recognize, can be installed in a piece of machinery. So that’s one of those things that this does not have to be expensive now, and these kinds of things, I mean, you can buy that on Amazon. They are designed for that purpose, you buy a $5,000, Jet bandsaw, it has that exact switch in it. These are things that you can do that are inexpensive that there’s no reason not to do on all tools and machinery in your facility. Now, as you move up the road you get things that have anti restart that are in line. There are some places that a momentary footswitch can be considered – both anti restart and sometimes as an E-Stop replacement. OSHA has some code clarifications where they talk about specifically pipe threads and how having a because it’s sometimes hard to do controls to their directional and it can get a little more complicated. They’ve allowed things like a momentary footswitch to be considered as a way to disconnect and things like that. So, that could apply to you. There’s also these UL508A control boxes they’re kind of the Lincoln Log/Lego version of a way to get anti restart that we talked about and E-Stop we haven’t talked about E-Stop a lot.
Depending on interpretation, it can be required or not required but it is something that I would argue is good to have everywhere. And then four and these are available from every manufacturer you can imagine you go to on Stronghold, Guardomation, Rockford Systems, they all sell their own flavor of this. Not super expensive. And then I mentioned the anti-restart and E-stop, you have products like ours. Ours is also in that plug and play tech category. You just plug it in. And then for hours, you would get the anti-restart that E-stop, you also get motor braking, which is new. I’ll plug that a little later. Then of course, you can build a custom control cabinet. And you can make that do anything you want. The sky’s the limit. There’s this huge spectrum. And as you’re shopping, you want to be looking for is it listed by a recognized or is it listed by a nationally recognized test lab for that purpose? You also of course, want to check this out the voltage and current horsepower requirements, what you need. And then you say, Is it something that we have the expertise to install ourselves? We’re willing to rewire something, okay. You can put in a magnetic switch. super inexpensive. You’d rather have something that’s plug and play. You just plug it in. You’re back up in this territory. In the penalties control boxes are one of our products. Or you have other needs. And this is where when you have those other kinds of energy we were talking about maybe you have something pneumatic, there’s more complication than it’s a simple on off piece of machinery. You really start wanting to get into these custom control cabinets, which on their own if you’re doing everything aboveboard means that you would likely hire someone, they will use all Test Lab recognized components. And they will install them and arrange them in an agreed on way by the test labs and then that what’s called a panel shop actually has approval from test labs called Ul 508. A to basically say, Hey, we took all these recognized parts, installed them in agreed on way and we put a sticker on it saying this whole thing this whole control cabinet is now itself A listed assembly, we could go into the test labs at another time. But as with all safety things as for anything on here, once you install it, you test it.
That’s huge. Once you actually say these are our requirements for what these controls have to do, you install it and then you go down that list and say, does it do? Does it reset automatically? Does it start the machine when we reset the stop? It better not. Test it and see, people make mistakes.
I was helping with an injury study recently where there was a large press break. And what we found or what we suspect happened based on the information is that there was a strange race condition. Meaning that two outcomes are possible where if someone was depressing a pedal when they press the safety switch, it was a game of chance on whether the safety switch would work or not. That was an oversight by an engineer at some point, we’re all imperfect. That’s why you really want to be testing this thing.
I see a question in the chat about how would you know if a product is UL 508? That’s a great question. So you would know because literally on the product, there will be a mark for UL. It would be a little UL with a circle. If it is a listed product, I mean, it’s a full assembly that is safe to install. If it was CSA, it would be the little CSA with the half thing. I have some links back in the presentation, which I will share. That has all the different marks. And right next to that it should have one of two things. If it’s a listed product, it will actually say the standard that is listed under it and it’ll normally have the number and the description. And then secondly, it will also have a license number or their kind of certification number. That’s all public. Part of this I learned. So, I see a product. And I say that’s interesting. And I just look up that number. And on the UL website, you can see, all these particular products are listed for these particular uses. And it gives you all the information in a different one, or ask around, ask someone that knows, that’s always a good way to go.
We’ve covered quite a bit. I just want to summarize really quickly and say, we talked about this petition, this petition specifically says we want to clarify and move that anti restart requirement into somewhere that machine guarding people are going to see it. And my initial conversations, this is going to be probably a 12 to 18 month process, but my initial conversations look like that is likely to happen. And then secondly, was that what I would call either mis-marketing or mis-labeled or misleading advertising that has led to these kinds of appliance controls being used is that Cal OSHA does not regulate NRTLs, fed OSHA does. There’s gonna be some switching around. I may file a formal complaint with the test labs, I’m still figuring out the best path for that one. But I did want to just make sure that everyone is aware of that. And then also you have the basics you need and again, I’m going to share the presentation and the video to go out, test if your equipment is compliant with this one simple requirement. Will your machine restart after a power loss? That’s one of the things you can test all your machinery for today. And then if it does not comply, start shopping, buy some stuff that’ll, that’ll help you get those into compliance, and and to keep moving forward.
So what I’d like to do is as we’re summarizing, we’re going to have a little q&a. But I know since MCs safe is sponsoring this event, I just want to give you a quick look at what our products are just about a one minute video, and then we’ll dive into q&a. I’m going to share this quick video with you all from right here in San Diego. My name is Scott Swaaley. And I’m the founder of make safe tools. We’re here at the NSC Expo in San Diego, California. And we’re showing our make safe tools power tool bring. So here it is installed on a one and a half horsepower bandsaw. You come on and I’ll show you some of its features. One which is really interesting is this device is actually just plug and play, meaning that we did not modify this bandsaw we simply plugged the bandsaw into this device and this device into the wall. That now gives us this control panel down here, which has an NC compliant emergency stop and a green Start button and this is our now how we control this bandsaw and I’ll show you some normal operation. We can now start to ban And what is really interesting is now when we stop it, we take a bandsaw that typically just takes about 40 seconds to stop. And if we zoom in on the blade here, you’re gonna see that when I press stop, now, it actually comes to a complete stop in just one second, making it much safer to operate, making it safe to reach for your cutoff once you complete an operation. Additionally, this provides an accidental restart prevention meaning that if there’s a loss of power, you will not have your tool come on and surprise you, which is an OSHA requirement.
And lastly, as we mentioned before, you now have a fancy compliant emergency stop button you can position anywhere that it’s convenient. With this added to a bandsaw, or a branch grinder or a descender you can make your shop safer without having to worry about installs, electricians or anything like that. All right, so a couple just things for the eagle eyes out there. Someone might say hey, there was an E-Stop being used for normal stopping. So, yes, Eagle Eyes, we offer a lot of different control panels. Our standard one is actually a three button with a separate stop.
And I do see a question. So I’m going to look over. Obviously we’re a product company but we are happy to answer any questions. I like doing this research. It really helps keep us informed and it helps us to help everyone else. If you have specific questions, we’re happy to research with you and help however we can. Dallas has a question. He says how do you protect for restart on portable tools like handheld routers. This is a tricky one. And I was just talking or researching this recently, and the handheld tools are not covered by the anti restart requirement. I shared a second ago there actually one of the exclusions, but theoretically, the actual ul listing process for a particular portable tool may require it that way. And often, I haven’t read through all those standards in detail. I’m using some contextual understanding here, that they can’t be easily or mistakenly activated, but that there isn’t an explicit ul requirement that they have accidental restart installed. So what you could do is on those, you could get one of those less expensive inline plugs and literally it just plugs on the end and dangles there with the cord. You could even zip tie it on or something if you want to make sure people don’t remove it.
And so you would end up going through basically the exact same process, just probably looking for something that is more of an inline device just for convenience with those portable hand tools. But also, you can look for portable hand tools that have a momentary button. If you think about, let’s say, an angle grinder, which are notoriously hazardous devices, there used to be a lot more angle grinders that had the locking on switches, they’d have a whole bar on the handle that you could lock in and on position. So then when you unplug it and plug it back in, it would turn on. So you will see some devices that have automatic releases, where they will automatically release that button when power is restored. And that’s more of a shopping for the feature thing if you don’t if you can’t find something that has that built in. So another anonymous attendee asked Are these things Cal OSHA or fed OSHA requirements? Good question. The petition I talked about was specifically about a Cal OSHA requirement but fed OSHA also has an accidental restart prevention language.
And there’s a few things to talk about here. One is the explicit mention of it in, in what are the 29 CFR 919 10. And then the woodworking section for some reason the woodworking says specifically that anything that could create a hazard when restarting should have accidental restart prevention. However, I have seen it enforced outside of woodworking equipment, often on some of these smaller machines. Then we also kind of go back into the FPGA world, where we’re talking about any motor that gets installed. And you could argue with that, if you buy a bandsaw you’re not installing a motor you’re installing a saw and yeah, there’s some great area. So I hope that helps. Another question from Dan Hopwood is the current configuration of your product, I think it means Rs, like the one in the video, can you inadvertently hit the start button after a normal stop? Or is the commercial version supply to hood or resets for tech? So I think they’re asking: can you have a recessed start button. We have a variety of, of controls ranging from different actual little control panels like that to foot pedals and can do a lot of different ways. Depending on the needs and the tool, we do it different ways. Our new buttons are flush, they’re a little more protective of the accidental presses.
Cool. So if you have any other questions, or you’ve seen or any, or any anything else, go ahead and put it in the chat, put it in the q&a, and if You. If that’s it, we want to thank everyone for coming. We want to thank the ASSP for organizing this event, we will be sending out the recording of the webinar as well as the the PowerPoint to all registered attendees probably by the end of the day. And if you have more questions, we’re going to stick on here for a little bit more, and we see some people… Dallas, who’s awesome, at a local company saying that he uses our devices and loves them. Thank you. Thank you. And then I see some other people talking about how the cost can be hard for people, especially with lockout tagout, and things like that. And the things I always say is I understand that there’s costs. And what I find though, in my research, and I mean, we’ve been working with NIOSH to do research on exactly these topics, is that it’s often the difficulty of intention and time to plan.
That’s a bigger driver than calling But these little things that I was showing a $20 switch. You could put that on every tool in your facility for a couple hundred bucks. And that only takes you know, someone that’s a little electrically competent, maybe 10 minutes a tool. It’s often just what I find, the mental space to wrap our heads around it and say, okay, we are going to do this one thing. And we’re gonna, you know, we’re not maybe perfect yet, but we have a plan for over the next five years. We’re going to, you know, this month we’re going to look at accidental restart prevention. Great. We spent a couple hundred dollars a couple days of someone’s time we’ve got those implemented.
Okay, next month, we’re going to be doing an evaluation for this and you can roll that out piece by piece, because I find the best way to start anything is to start, even if it seems like a trivial start, it can make a really big difference. I see a question from Martin about something about a valve shut off safety research. I think you’re talking about Other kinds of hazardous energy. We don’t do that there are a number of companies that kind of integrate with more full service, but you really quickly get into having to do custom control panels. because no two, no two situations are ever quite alike. So there’s not a lot of commercially available things to do all of those. Let’s see. Yeah, and Allah has a good point that, you know, we’re talking about regulatory requirements. But in the end, it’s, it’s also that we’re trying to keep people from getting hurt. And especially when someone gets hurt there are some crazy circumstances. We can’t protect from everything, right? We never can. But when we see injuries happening that are so easily preventable, that’s what ends up irking me personally. Just thinking about what can we do that can make a difference.
So, I want to make sure that we respect everyone’s time. Thank you. again for attending and if you have any questions that we didn’t get to in this, my email is on the screen. Go ahead and shoot me an email, give me a call and we’d love to chat. Thanks again everybody and have a wonderful day.