Federal Register - March 2, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 39 / Tuesday, March 2, 2021 / Notices
lock, move the slide bar back to allow the door to shut, and shut the door.
6. Once cleaning of the laser cell is complete and all employees are clear of the restricted area, place the laser HMI
back into production by placing the Series Production from Single Job to Continuous Job by clicking the Continuous Job button.
7. After the HMI has been released to production, press the green button which resets the light curtains and causes the robot to place the next part on the turntable.
Process To Restart Trumpf Laser Cell After Door Is Opened
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1. Remove all padlocks from mechanical latch from the far access door.
2. Open the mechanical latch.
3. Visually inspect area for the presence of persons or tools.
4. Close the far machine enclosure door.
5. Walk to near access door.
6. Remove all padlocks from mechanical latch from the near access door.
7. Open the mechanical latch.
8. Visually inspect area for the presence of persons or tools.
9. Press the reset switch on inside of the machine enclosure.
10. Close the door within 34 seconds of pressing the reset switch.
11. Turn the key switch on the HMI
to enable operations.
12. Engage HMI to activate laser.
13. Enable continuous mode operation push button within HMI.
The proposed door latch system cannot be easily defeated or tampered with. Gestamp asserts that this alternative meets the requirements for control reliability as stated in ANSI
B11.0 and ANSI Z244.1, in that no single fault of a component, wire, device or other element will result in the loss of the safety function.2 According to the variance application, in the event of a fault, the laser will achieve a safe state by inhibiting lasing, machine motions, and the release of hazardous energy. In addition, the system includes system fault monitoring, tamper resistance, and exclusive employee control over lockout devices. The Trumpf laser machine 2 ANSI B11.0 defines control reliability as the capability of the machine control system, the engineering control devices, other control components and related interfacing to achieve a safe state in the event of a failure within the safetyrelated parts of the control system.
ANSI Z244.1 defines control reliability as the capability of the machine, equipment or process control system, the safeguarding, other control components and related interfacing to achieve a safe state in the event of a failure within their safety-related functions.
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enclosure has a door interlock switch that is integrated to the laser and machinery motions. When the door to the laser cell is open, the release of laser energy is inhibited and the machine axes cannot move; therefore the laser will not operate.
To enhance the lockout functions of the Trumpf laser cell, Gestamp added red mechanical latches to the external side of each entry door to the laser cell.
The lockable interface switches used with the mechanical latches are designed to be used as lockable devices.
The circuitry of the lockable interlock switches inhibit both machinery motions and laser energy release with the Trumpf enclosure door switches and will not operate when disengaged.
C. Technical Review OSHA conducted a review of Gestamps application and the supporting technical documentation.
After completing the review of the application and supporting documentation, OSHA concludes that Gestamp:
1. Modified the access door with red mechanical latches with a slide bar to prevent the door from being closed while cleaning activities are performed within the laser cell;
2. Installed a personal lock control system and implemented administrative energy control procedures that prevent employee exposure to hazards associated with energy while performing cleaning activities within the laser cell;
3. Performed a job hazard analysis for tasks associated with cleaning the laser cell and conducted and documented an electrical isolation analysis, system and functional safety reviews, and control reliability analysis to verify that the use of the latch system and administrative energy control procedures prevent the closure of the doors to the laser cell, prevent mistaken or intentional reenergization, and maintain immobility in the event of fault conditions;
4. Developed detailed administrative energy control procedures for entering the laser cell to perform cleaning functions and distinguished these work procedures from other tasks that require full lockout;
5. Implemented detailed administrative energy control procedures designed to ensure that each authorized employee applies a personal lock to the secondary group lock box;
6. Made the administrative energy control policies and procedures available to employees;
7. Trained authorized and affected employees on the application of the proposed alternative work practice and
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associated administrative energy control policies and procedures; and 8. Developed a LOTO procedure which includes administrative controls to minimize the potential for authorized and affected employees to enter the laser cell when harm could occur.
After the technical review identified above, OSHA concludes that Gestamp has established an alternative work practice that provides workers protection equivalent to that required by the standard. Specifically, the LOTO
process for the Trumpf laser cell identified in the variance application regulates the control of hazardous energy from the laser during the maintenance task of cleaning.
III. Description of the Conditions Specified for the Permanent Variance As previously indicated in this notice, OSHA conducted a review of Gestamps application and supporting documentation. OSHA determined that Gestamp developed and proposed to implement effective alternative means of protection that provides protection to their employees as safe and healthful as protections required within paragraph 1910.147d4iii of OSHAs LOTO standard during the maintenance task of cleaning the Trumpf laser cell.
Therefore, on August 5, 2020, OSHA
published a Federal Register notice announcing Gestamps application for a permanent variance and interim order, grant of an interim order, and request for comments 85 FR 47422. The agency requested comments by September 4, 2020. There was one comment received in response to this notice in support of the application OSHA201900040006, however this comment did not require a response from OSHA.
During the period starting with the August 5, 2020, publication of the preliminary Federal Register notice announcing grant of the Interim Order until the agency modifies or revokes the Interim Order or makes a decision on the application for a permanent variance, the applicant was required to comply fully with the conditions of the Interim Order as an alternative to complying with the requirements of paragraph 1910.147d4iii. With the publication of this notice, OSHA is revoking the Interim Order granted to the employer on August 5, 2020.
This section describes the conditions that comprise the alternative means of compliance with 29 CFR
1910.147d4iii. Also, these conditions provide additional detail regarding the conditions that form the basis of the permanent variance OSHA
is granting to Gestamp.
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