Chapter 25 – Machine Safeguarding – Shop and Laboratory Machine Safety

Contents

Approved by Herb Toor
Revised 8/24

25.1 Policy 
25.2 Scope 
25.3 Applicability 
25.4 Exceptions 
25.5 Roles and Responsibilities 
25.6 Definitions 
25.7 Required Work Processes 

• Work Process A. General Requirements 
• Work Process B. Procurement and Installation of Machine Tools, Machine Equipment, and Guarding 
• Work Process C. Authorization and Qualification 
• Work Process D. Machine Tool and Machine Equipment Guarding Requirements 
• Work Process E. Inspection and Maintenance 

25.8 Source Requirements 
25.9 Reference Documents 
25.10 Appendices 

• Appendix A. Example of an Application to Use Shop Equipment 
• Appendix B. Berkeley Lab Nonlaboratory Machine Guarding Requirements 
• Appendix C. Berkeley Lab Laboratory Machine Equipment Guarding Requirements 
• Appendix D. Machine Tool, Equipment, and Power Tool Safety Checklist

Note:
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25.1 Policy

The Machine Safeguarding — Shop and Lab Machine Safety Program at Berkeley Lab assures that machine tools, power tools, machine equipment, and robotics in shops, laboratories, equipment rooms, on construction sites, and at other locations are properly guarded and used safely. 

• Division line management must provide machine guarding and to ensure it is used to protect operators, researchers, and other employees from hazards. 
• Machine tools, machine equipment, and power tools may only be operated and/or maintained by authorized personnel working in accordance with the requirements of this chapter.

25.2 Scope

This program’s scope includes Berkeley Lab work in areas where machine equipment, machine tools, and/or power tools are located. Areas include but are not limited to shops, laboratories, mechanical rooms, and construction sites.

25.3 Applicability

These safety requirements apply to all Berkeley Lab employees, subcontractors, vendors, and affiliates who work with or perform maintenance on machine tools, machine equipment, or power tools.

25.4 Exceptions

None

25.5 Roles and Responsibilities

Role	Responsibility
The Health and Safety Department (Environment, Health & Safety [EHS] Division)	Provides expertise on machine-guarding requirements, and on machine-tool, power-tool, machine-equipment, and shop safety
Machine Tool Services (Engineering Division)	Repairs and maintains mechanical tools and equipment
Electric Shop (Facilities Division)	Maintains electrical utilities
Berkeley Lab Division Directors	Identify a home division responsible person for each shop/lab Designate qualified shop managers for each shop under their responsibility
Supervisors, Work Leaders, and Shop Managers	Ensure that all requirements of this chapter are implemented for operation, maintenance, and repair of machine tools, machine equipment, and power tools under their control Enforce safe operation and maintenance of machine tools, machine equipment, and power tools Remove from service, label, and secure any equipment/tool that is damaged, in disrepair, or deemed unsafe
Qualified and Authorized Employees (and other users of machine tools, machine equipment, and power tools)	Observe all established safety regulations relating to operation and maintenance of machine tools, machine equipment, and power tools Operate and/or maintain machine tools, machine equipment, or power tools only if they are qualified and authorized to do so Adhere to all applicable safety requirements, rules, and regulations Provide suggestions on improving existing safeguarding Report any improperly functioning machine or tool or those that lack safeguards for all points of operation or rotational motion, including nip points and cutting, shearing, punching, and forming mechanisms Wear appropriate clothing when performing a job (for example, covering skin where necessary, wearing no loose-fitting clothing or jewelry near rotating equipment, and wearing suitably heavy shoes) Operate machine and power tools safely, and maintain machine tools, machine equipment, and power tools in good mechanical and operating condition Immediately report any machine or tool with signs of excessive wear or with damaged or misused parts (e.g., a lathe leaking an excessive amount of oil, or a drill press that appears to have a faulty chuck that does not secure the tool)

25.6 Definitions

Term	Definition
Authorized Person	An individual approved or assigned by line management to perform a specific duty or duties, or to be at a specific location or locations at the workplace
Qualified Person	An individual who through experience, sufficient knowledge, or training can operate specific machine tools, power tools, and/or machine equipment safely, and identify and mitigate hazards associated with the use of such equipment
Machine Equipment	Any piece of machinery not described below as a tool. Machine equipment includes building systems equipment such as building HVAC systems, air compressors, and mechanical pumps, as well as scientific equipment such as centrifuges, tensile test machines, sample polishers, etc.
Machine Tool	Any fixed (nonportable) or tabletop machine used to cut, shape, or otherwise alter materials. Machine tools are not limited to shops and may be found in other areas, such as laboratories and construction sites. Machine tools include but are not limited to machine-shop tools (saws, lathes, grinders, milling machines, drill presses, etc.), woodworking tools (table saws, jointers, planers, etc.), and specialized shop tools (pipe cutters/threaders, power shears, power brakes, rolling mills, swaging equipment, etc.). The term “shop tool” is loosely synonymous with “machine tool.”
Power Tools	Portable machine tools (hand drills, hand grinders, circular saws, routers, etc.)
Shop	Any area designated as such by line management, in which one or more machine tools and or power tools are used

25.7 Required Work Processes

Work Process A. General Requirements

Machine tools, power tools, and machine equipment can cause serious injuries, amputations, and even death. Traditionally, the use of such equipment is restricted to technical and/or crafts personnel trained in the proper application, operation, or maintenance of such equipment.

1. General Safety Rules for Power Tool Use 
   1. The following rules apply to the use of power tools, regardless of their location.
      1. Only qualified personnel with necessary skills through experience and/or training, and who have been appropriately authorized through a Work Planning and Control (WPC) Activity as determined by division line management, are permitted to operate power tools.
      2. A formal authorization (i.e WPC Activity) is required for use of power tools that expose personnel to injury, even if they are tools commonly used by the public. Examples include circular saws, nail guns, and Roto Hammers. Power tools that pose minimal hazards and are commonly used by the public may be used without authorization. Examples include ⅜-inch chuck-size drills, impact wrenches, electric screwdrivers, and electric bolt drivers.  
      3. All required guards and personal protective equipment (PPE) must be used.
      4. All personnel must wear required PPE when entering areas where power tools are operated and/or other hazards exist.
      5. Persons under the age of 18 are prohibited from operating any dangerous power tool unless the work is part of an approved apprenticeship program. Dangerous tools include but are not limited to circular saws, chain saws, high-torque drills, and abrasive wheels greater than 2 inches in diameter.
      6. Only qualified (trained and certified) and authorized personnel are permitted to operate powder-actuated (i.e., cartridge-actuated) tools. A penetration permit must be acquired from the Facilities Division as required by Facilities Division Administrative Procedure 053: Permit to penetrate ground or excavate surfaces of LBNL property.
      7. Ground fault circuit interrupters (GFCIs) must be used on all cord-and-plug electric power tools employed in construction, outdoor, or damp location work.
      8. Fuel-powered tools may not be used in indoor locations unless their use has been approved by the EHS Division’s Health and Safety Department. Fuel-powered tools must be shut down before refueling, servicing, or maintenance. Fuel must be handled and stored in accordance with Cal/OSHA CCR Title 8, Construction Safety Orders (CSO), Article 36, Fire Protection and Prevention.
      9. Only qualified and authorized personnel or vendors are permitted to repair or otherwise service power tools.
2. General Safety Rules for Use/Maintenance of Machine Tools and Machine Equipment 
   1. The following general rules apply to the use and/or maintenance of machine tools and machine equipment, regardless of their location.
      1. Only qualified personnel with necessary skills through experience and/or training, and who have been appropriately authorized through a WPC Activity as determined by division line management, are permitted to operate or maintain machine tools or machine equipment.
      2. All machine tools, power tools, and machine equipment must be equipped with all required guarding; operating such equipment without fully functional required guarding is prohibited. Equipment without required functional guarding must be locked and tagged.
      3. Machine tools and machine equipment must be operated and maintained in accordance with the manufacturer’s requirements and the requirements of this chapter. All machinery and machine equipment designed by the manufacturer to be stationary must be anchored and electrically wired. Only qualified electricians may install and remove wiring for hardwired shop machinery and machine equipment. Machine tools and machine equipment designed to be electrically connected by cord and plug are not subject to this requirement.
      4. Only qualified and authorized personnel or vendors may repair or otherwise service machine tools or equipment. 
      5. Machine tools may only be operated when a second person is within sight or earshot of the tool user. This is an essential requirement in the case of personnel who get caught in machinery or suffer traumatic injuries. The second person need not be qualified to operate the equipment but does need to know how to turn it off and how to call for emergency assistance. This second person must agree ahead of time to perform such duties should the need arise. A check-in and check-out protocol must be established.
      6. All machine and tool guards must be installed in place, in good working order, properly adjusted, and most importantly, used for their intended purpose. This includes the use of chip shields for any drilling or cutting operations.
      7. Personal Protective Equipment 
         1. At a minimum, safety glasses with side shields must be worn while in the vicinity of operating machine tools. This applies both to workers and to visitors. Face shields or goggles should be worn, as required by work authorization for specific operations.
         2. Substantial closed-toe footwear of sturdy construction, made of leather or other heavy, solvent-resistant material, should be worn. When there is a risk of crushing or piercing, approved safety shoes meeting ANSI Z74.1 are required. Personnel, including visitors, may not enter the work area with sandals or open-toed shoes.
         3. Appropriate clothing must be worn.
         4. Hearing protection and/or respiratory protection must be used as required by work authorization for operations that generate harmful noise or airborne emissions. Contact the Health and Safety Department for assistance in determining which operations require such protection.
      8. A worker operating machine or power tools must not use audio equipment that obstructs the ear canal (e.g., an iPod) or cell phone Bluetooth headset. Such devices distract the operator and can prevent him or her from hearing sounds that could provide warning of an unusual operating condition or someone calling out for assistance.
      9. Personnel under the age of 18 are prohibited from operating any machine or power tool unless the work is part of a state-approved apprenticeship program.
      10. Long hair should be tied back or secured; long sleeves must be cuffed or rolled up; loose jewelry should be removed or taped down when working with rotating machinery.
      11. Food should not be prepared or consumed in areas where hazardous materials (including oils, solvents, chemicals, cuttings, filings, and sawdust) are handled or generated. If necessary, a food and drink preparation/consumption area should be designated in an area kept free of hazardous materials at all times.
      12. Where applicable, work pieces should be secured and clamped down in work-holding devices and machines to prevent work from being lifted or dislodged.
      13. To keep hands and fingers well away from moving or rotating cutters, blades, and other points of operation, workers should use push sticks or other approved methods as indicated in the work authorization.
      14. The machine must be turned off before using a brush or wooden dowel (not hands!) to remove chips from the machining area. Chips are not only very sharp but can be hot and can snag.
      15. Good housekeeping must be maintained. Work is not complete until cleanup is done. Debris, coolants, and lubricants can cause cuts, slipping, and skin irritation. Work areas must be cleaned with a broom, brush, and dustpan. All spills should be cleaned with absorbents and/or degreasers. Compressed air should not be used to blow chips off machinery: It is a hazard to the eyes; forces material into the precision inner workings of the machine; and often distributes coolant, oil, and chips over a larger area. The machine should be cleaned and the floor swept of any remaining chips. Contact the Facilities Division for assistance in removing oily buildup from floors.
      16. Line management in the shop’s division must ensure that all shop work is monitored by a qualified shop manager. Contact the Shop Safety Subject Matter Expert (SME) to help determine which individuals are qualified to serve as shop managers. The shop manager’s name must be posted at the entrance to the shop.
          1. The qualified shop manager must:
             • Demonstrate experience in the safe operation and maintenance of machine and power tools.
             • Determine whether other personnel are qualified to operate specific machine and power tools in the shop.
             • Determine who may use the shop machine and power tools, and how and when they may do so.
             • Ensure that only qualified and authorized personnel operate the shop machine and power tools.
      17. Only personnel who have been explicitly approved by the shop manager and authorized by line management are permitted to operate the equipment in the shop.
3. Safety Rules for the Use and Maintenance of Laboratory-Specific Machine Equipment 
   1. The following rules apply to Laboratory-specific machine equipment: 
      1. Appropriate guards must be in place, and a safe operation/maintenance procedure created, as applicable for Laboratory-made equipment. Examples of hazards that require guarding include points of operation where personnel can be pinched, nipped, crushed, burned, or cut, such as in presses, heat sealers, polishers, rock-cutting equipment, or in rotating transmission components such as belt drives, gears, and rotating shafts over 10 rpm. 
      2. Appropriate guarding must be verified, and workers must follow the manufacturer’s operation and maintenance procedures for procured equipment. 
      3. Only authorized and qualified personnel are permitted to operate Laboratory equipment when there is potential for exposure to injury (e.g., where guarding or other controls can be easily defeated). 
         1. A formal authorization (WPC Activity) is required for using Laboratory equipment that exposes personnel to injury. Examples include centrifuges without interlocking lids, microtomes, high-torque mechanical stirrers, and unguarded shaker tables. 
         2. Formal authorization and guarding are not required for operating Laboratory equipment that cannot cause injury. Examples include centrifuges with interlocking lids, vortex mixers, mechanical stirrers, rotary evaporators (rotovaps), guarded vacuum pumps, and guarded orbital shaker tables.
      4. PPE should be worn that is appropriate for the hazard (e.g., lab coats, safety glasses, goggles, face shields, gloves, long pants, closed-toe shoes, etc.). The EHS Division’s Health and Safety Department can assist with proper PPE requirements.
      5. Only qualified and authorized personnel or vendors are permitted to repair or otherwise service Laboratory equipment. 
4. Safety Rules for Use and Maintenance of Office Machine Equipment 
   1. The following rules apply to office-specific machine equipment:
      1. Appropriate guarding must be verified, and the manufacturer’s operation and maintenance procedures must be followed for procured equipment. Examples of required guarding include paper-cutter guards and copy-machine interlocks, which prevent the machine from operating when doors are open.
      2. Salvaged equipment must have all appropriate guards in place. The EHS Division’s Health and Safety Department can help with guidance.
      3. Office equipment commonly used by the public does not require formal authorization to operate. 
      4. Only qualified and authorized personnel or vendors are permitted to repair or otherwise service office equipment. 

Work Process B. Procurement and Installation of Machine Tools, Machine Equipment, and Guarding

1. All new machine tools and equipment must be procured with all guarding required by Cal/OSHA CCR Title 8 and, when applicable, by national consensus standards applying to the specific equipment. These guarding requirements should be specified in the requisition to the vendor so that they can be furnished with the equipment.
2. If purchasing used equipment, acquire and retrofit all required guarding before the equipment is placed in service. The cost and difficulty of retrofitting should be considered to determine whether surplus equipment is a prudent acquisition.
   1. The Shop Safety SME or the Engineering Division Machine Tool Repair and Maintenance Group can assist in determining which guards are required, where to purchase them, and how to install them.
3. All newly acquired equipment must be secured to Cal/OSHA machine safety and LBNL seismic safety standards, and wired as described in Section 25.10(d), by qualified electricians within current electrical code requirements. The Machine Tool Repair and Maintenance Group in the Engineering Division assists with securing equipment, and the Facilities Division Electric Shop can assist for electrical installations.

Work Process C. Authorization and Qualification

1. At Berkeley Lab, other personnel may operate machine and power tools to help construct or modify experimental equipment or components. When required by the level of hazard, this work is authorized by division line management with a WPC Activity. Work is planned and carried out by personnel who have been assessed by line management for their skill, knowledge, and abilities to perform the specific tasks with these tools.
   1. If a worker’s skills, knowledge, abilities, or resources are insufficient to operate or maintain machine and power tools within the constraints of this chapter, the Engineering or Facilities Division shop managers must be contacted so that the work can be performed by skilled technical or crafts personnel.
   2. When the level of hazard requires it, the operation and maintenance of machine equipment other than machine tools requires division line management authorization. Authorization verifies that line management has ensured that workers have the necessary skills, knowledge, and abilities to operate and/or maintain the machine equipment.
   3. Authorization exists for the repair, maintenance, and operation of building system machine equipment by appropriate Facilities Division HVAC and Electrical Shop personnel.
   4. There are no formal LBNL training courses covering the technical use of machine tools, machine equipment, or power tools. Employees and managers are qualified through trade experience, equipment manufacturers’ courses, documented on-the-job training (OJT), and/or demonstrated skill and abilities on the use of equipment within designated areas (shop, lab, facility, fieldwork location, etc.) in which they work. 
   5. While certain Facilities Division Heating, Ventilation, and Air Conditioning (HVAC), plant maintenance technicians (PMTs), and Electrical Shop employees are qualified through trade experience, OJT, and/or demonstrated skill to maintain and operate most building system machine equipment, new or unique machine equipment may require specific training from the manufacturer. 
   6. Line management is expected to evaluate employee skill levels prior to assigning work. If an employee is hired to perform a skilled trade in which he or she is qualified, or has extensive experience operating a particular piece of equipment, a WPC Activity provides sufficient training documentation. Except as noted, the WPC process ensures that the employee authorized to use a machine tool, power tool, or piece of machine equipment is qualified to do so.    
   7. At the discretion of division management, additional safety training for shop/laboratory managers may include understanding their scope of responsibility, EHS requirements, oversight and observation, as well as coaching and mentoring techniques.

1. Qualifying Research Personnel to Perform Work in User Shops 
   1. Research personnel who wish to become qualified to perform limited shop work need documented OJT specific to the machine tool in question. This may be achieved by using the optional Application to Use Shop Equipment (Appendix A), or an approved equivalent qualification process. The Shop Safety SME may approve qualifications processes found to be equivalent to the application process.
      1. If choosing to use the application process, potential users must first submit an Application to Use Shop Equipment for each piece of equipment they want to use to their division shop manager or the Engineering Division Researcher Shop in Building 77. The shop manager or Engineering Division representative reviews the application and administers a safe operation skills check for each machine. The shop manager or Engineering Division representative may deny qualifying individuals who do not exhibit the ability to safely operate the piece of equipment, or in cases where the equipment requires a higher level of training to acquire the necessary qualifications. Based on the hazards of the machine, the shop manager and/or work authorization may require documented OJT in addition to the safe operations skills check.
      2. Personnel not qualified to operate machine or power tools may choose to contact their local division shop manager or the Engineering Division to have the fabrication/modification work done for them. 

Work Process D. Machine Tool and Machine Equipment Guarding Requirements

1. Line management must ensure that machine-tool and machine-equipment guarding is adequate. Factory-installed guards must not be removed unless they are designed to be removed for a particular operation, and equivalent means of protection are used (e.g., table saw guards are removed for fence cuts; when appropriate, push sticks are used).
   1. All reasonably accessible points of operation, pinch and nip points, rotating parts, and flying chip or spark hazards that may expose an employee to injury must be guarded. In general, guarding prevents inadvertent contact with these hazards. Guarding may be achieved by one or more methods, such as isolation, barriers, shields, devices, or distance. 
   2. LBNL follows Cal/OSHA machine-guarding standards, which address specific requirements for many types of machine tools, machine equipment, and power tools. While these standards are accessible to anyone, the Shop Safety SME provides guidance and interpretation of machine-guarding requirements. While most operators and managers can identify obvious machine dangers, they may not know how to identify or handle subtle machine hazards. The Shop Safety SME is a resource to help determine whether a machine tool, machine equipment, or power tool needs guarding.
   3. Appendix B provides a more detailed description of Berkeley Lab machine-guarding requirements; examples of machine hazards and guards; as well as a Machine Tool, Machine Equipment, and Power Tool Safety Checklist (Appendix D). The checklist may be used for self-assessments, walk-arounds, or inspections of areas where such equipment is located. 
2. Approach for Guarding Unique and Specialized Laboratory Machine Equipment 
   1. While OSHA requires guarding for certain highly specialized and unique Laboratory machine equipment to prevent employee injury, the guarding may not be included by the manufacturer. This may also apply to legacy Laboratory-designed and -built (homemade) equipment. In these cases, alternative guarding/and or controls may be designed. The Shop Safety SME can help assess guarding requirements and options. 
   2. Appendix C provides a more detailed description of LBNL Laboratory machine-equipment guarding requirements, examples of Laboratory machine-equipment guards.  A Machine Tool, Machine Equipment, and Power Tool Safety Checklist is provided in Appendix D. The checklist may be used for self-assessments, walk-arounds, or inspections of areas where such equipment is located.

Work Process E. Inspection and Maintenance

Machine tools, machine equipment, and power tools should be routinely inspected for damage, that the controls function as designed, and that all guarding and shields are securely installed and adjustable. Servicing—including cleaning, lubrication, preventive maintenance, and adjustment of machine equipment and machine tools—can help prevent performance and safety problems. Only qualified technicians authorized by line management or qualified vendors are permitted to service equipment. Equipment can be serviced only when all electrical, hydraulic, compressed air, and stored-energy sources are secured in accordance with the requirements of ES&H Manual Chapter 18 Lockout/Tagout.

The Facilities Division HVAC, plant maintenance technicians (PMTs), and electrical shops are the only Berkeley Lab personnel authorized to maintain and repair building-system machine equipment. Subcontractors may be authorized to work on building-system machine equipment through the submittal review and approval process. Other machine equipment may only be maintained by qualified technicians authorized by division line management, or qualified vendors.

25.8 Source Requirements

• Cal/OSHA CCR Title 8, General Industry Safety Orders
• Cal/OSHA CCR Title 8, Construction Industry Safety Orders

25.9 Reference Documents

ES&H Manual Chapter 18, Lockout/Tagout Program

25.10 Appendices

Appendix A. Example of an Application to Use Shop Equipment

Appendix B. Berkeley Lab Non-laboratory Machine Guarding Requirements

The Lawrence Berkeley National Laboratory (Berkeley Lab) machine-guarding program follows the requirements of Cal/OSHA, CCR Title 8, Subchapter 7.  Subchapter 7 contains sections addressing general requirements as well as machine-specific requirements. All machines, including machine tools, machine equipment, and portable power tools, must be guarded as required by Subchapter 7.

Subchapter 7 includes definitions, general requirements, and different kinds of machinery requirements.

• 1910.211, Definitions
• 1910.212, General requirements for all machines
• 1910.213, Woodworking machinery requirements
• 1910.214, Cooperage machinery [reserved]
• 1910.215, Abrasive wheel machinery
• 1910.216, Mills and calendars in the rubber and plastics industries
• 1910.217, Mechanical power presses
• 1910.218, Forging machines
• 1910.219, Mechanical power-transmission apparatus

Cal/OSHA requires employees to be protected from machine hazards such as dangerous points of operation, ingoing nip points, rotating parts, flying chips, sparks, etc. It also requires that certain protective measures be put in place, such as location (distance), barrier guards, two-handed tripping devices, and electronic safety devices where practicable and appropriate.

Specific regulations must be followed when machine tools or equipment Title 8, Subchapter 7. An appropriate alternate standard (e.g., ANSI) should be used when a specific Cal/OSHA regulation does not exist. If there is no ANSI or Cal/OSHA standard, Berkeley Lab may design one, as long as it prevents exposure to the machine hazards. The Shop Safety SME can offer guidance on guarding requirements or to provide machine-guarding design assistance. 

The example of a Machine Tool, Machine Equipment, and Power Tool Safety Checklist (Appendix D) can be used for optional documentation of self-checks, walk-arounds, or inspections of work areas (e.g., shops, laboratories, equipment rooms, etc.) where such equipment is located. 

 Some examples of machine hazards:

Some examples of machine guards:

Appendix C. Berkeley Lab Laboratory Machine Equipment Guarding Requirements

The Berkeley Lab Laboratory Machine Equipment Guarding Program follows the requirements of Cal/OSHA CCR Title 8, Subchapter 7, General Requirements, which mandates that employees be protected from machine hazards such as dangerous points of operation, ingoing nip points, rotating parts, flying chips, sparks, etc. It also requires that protective steps be taken, such as location (distance), barrier guards, two-handed tripping devices, and electronic safety devices where practicable and appropriate.

An appropriate alternate standard (e.g., ANSI) should be used when a specific Cal/OSHA regulation does not exist. If there is no ANSI or OSHA standard, Berkeley Lab may design one, as long as it prevents exposure to the machine hazards. The Shop Safety SME can provide for guidance on guarding requirements or to provide machine guarding design assistance. 

The example of a Machine Tool, Machine Equipment, and Power Tool Safety Checklist (Appendix D) should be used as optional documentation of self-checks, walk-arounds, or inspections of work areas (e.g., shops, laboratories, equipment rooms, etc.) where such equipment is located.

Some examples of Laboratory machine hazards and guards:

Appendix D. Machine Tool, Equipment, and Power Tool Safety Checklist

Performance Expectations

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