OSHA Amputation National Emphasis Program-Renewed

December 16, 2019

On December 10, 2019, the U.S. Department of Labor’s Occupational Safety and Health Administration issued an instruction (Directive)  CPL 03-00-022 cancelling the prior  NEP CPL 03-00-019 National Emphasis Program on Amputations, August 13, 2015, and describes the policies and procedures for the continued implementation of the National Emphasis Program  to identify and reduce Amputation hazards in Manufacturing Industries.

We covered the prior NEP notice in our post HERE

OSHA’s enforcement history shows that employees are often injured when machinery or equipment is not properly guarded or maintained.  This NEP targets industrial and manufacturing workplaces having machinery and equipment that can potentially cause amputations. Our 332- manufacturing NAICS codes are identified in this updated instruction.

See the source image

 

OSHA Instruction: CPL 03-00-022, National Emphasis Program on Amputations in Manufacturing Industries, is now available:

Directive Type: OSHA Instruction

Directive number: CPL 03-00-022

Directive subject:  National Emphasis Program on Amputations in Manufacturing Industries

Effective Date: 12/10/2019

Cancellation/Archive including PDF: CPL 03-00-019, National Emphasis Program on Amputations, August 13, 2015

https://www.osha.gov/enforcement/directives/cpl-03-00-022

To support the purpose of this NEP, OSHA is beginning a three-month period of education and prevention outreach to encourage employers to bring their facilities into compliance with OSHA standards.   Additional outreach and compliance assistance material will be forthcoming in the near future.

We will be providing reminders to our shops to retrain shop personnel in 1910.147 Control of Hazardous Energy and  1910.212 Machine Guarding – General Requirements. These are relevant to preventing amputations as well as being two of the 5 most prevalent general industry related violations in 2019.

We are hopeful that this time around, the Agency will give equal attention to enforcing part (b) of Section 5 of the OSH Act: “Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.”

OSH Act Sect 5 part (b)


C-1200 Series Steels- Not Recommended for Applications Requiring Mechanical Properties

December 10, 2019

Question: Why don’t the Certs for C12L14 and C1215 cold drawn steel bars have mechanical properties routinely reported?

Answer: Because these steels ARE NOT recommended for applications requiring mechanical properties, alternating stress applications, cold metal movement and can also be notch sensitive.

Don't do it!

Don’t use these steels for critical applications!

Here are some details from the application notes provided to me when I started as Plant Metallurgist at Bliss & Laughlin Steel in 1985:

  • The 1200 series steels (1215 and 12L14) are not generally sold for applications requiring high standards of strength, hardness, or other related properties
  • These steels are particularly adapted to automatic screw machine production of small repetitive parts. The ideal application is one where bulk and shape, as dictated by the design, are the chief requirements.
  • They may be used for parts which require only nominal strength values providing the factor of safety as in accordance with established practice. This is especially true where the stresses involved are static tension, compression, or shear. Vibratory, torsional, or alternating stress applications approaching the static limits are not recommended; thus these steels should not be used for line shafting.
  • When cold drawn, the C-1200 steels are notch sensitive and while polished fatigue specimens will show expected endurance limit values, poor finish and processing of parts, or faulty design may cause low or erratic results for finished parts under dynamic or alternating stresses of relatively small intensity.
  • These steels are not recommended for applications involving cold metal movement, such as crimping, forming or bending. Operations such as knurling and character rolling can be done satisfactorily.
  • Because of the smaller amount of hot work in rolling, the large size cold drawn C-1200 bars increase in relative brittleness.  The large sizes may also be expected to reveal stringer sulfide inclusions on polished surfaces. Further removal will likely reveal more inclusions as they are distributed throughout the bar cross-section.
  • A cold drawn surface will not plate to the highest quality finish; a turned or ground surface may prove necessary for critical applications

Your customer wants inexpensive parts, and machining them from 12L14 and 1215 minimizes the cost of machining to the desired geometry. But if the parts are not likely to fulfill the properties expected, that is false economy at best.

Don’t do it Image

Little Charlie and the Night Cats If you Dig It, Don’t Do it.


What About the Chips?

July 30, 2019

Our customers are interested in what is left after we remove the chips. But it is up to us  as operators and engineers to understand that there are differences in our chips based on process, material and tooling factors- and what those differences mean.

The infamous “Bird’s Nest Chip”

Process Differences

Turning can result in a long continuous chip, while sawing or milling processes result in shorter chips because of the interrupted nature of the cut. Drilling can result in the chips being recut depending on how the tool is fed and the nature of it’s spiral and means of chip evacuation.

Different materials can drive differences in the chips as well. I’m a steel guy, so my comments are based on that experience, but similar differences will be found in other materials, just based on different factors than Carbon.

Material Differences

Plain Carbon, Low Carbon Steels (C1008, C1010) tend to generate a more Continuous, Soft Chip. Plain Carbon, Medium Carbon Steels (C1030, C1045) can give a Continuous, Semi-Soft Chip. Plain Carbon, High Carbon Steels yield a Continuous, Hard Chip. Adding alloys can result in a Continuous, Semi-Hard Chip at lower carbon contents (4120) while higher carbon alloy steels can result in a Continuous, Tough Chip (4150) Very High Carbon Alloy steels (52100) give a chip that is both Continuous and Springy.

Having said that, I do not mean to say that all of these steels will result in long stringy chips- it is just that compared to Resulfurized Steels, such as 1117, 1144, 1215, or 12L14, the chips are far less likely to fracture into nice short pieces- often called “6’s or 9’s” or “C’s.” These chips can be described as Broken Semi-Soft (1117) or Broken Semi-Hard (1144) or Well-Broken Semi Hard (12L14, 1215)

Process Parameters

Finally, having the speed, feed, depth of cut, and angles on the tools is critical if we are to optimize material removal, minimize chip volume, and keep our process stable and maximize our uptime. Chip control features can also play an important role. ISO 3685 characterizes chips into 8 types- Ribbon, Tubular, Spiral, Washer-type Helical, Conical Helical, Arc, Elemental , and Needle chips. These can then be further described by length (short, long, or snarled).

Source ISO 3685

The ISO 3685 standard is a bit pricey, but it will help you to better understand what is going on in your turning process.

Of course you can look at the part, but to learn about your processes may I suggest that you take a really good look at the chips?


Quality Quote

October 10, 2018

No spec, no quality. Know Spec, know quality.

Quality means compliance with all terms of the specification.

Know the specification!


A New Era Began Today

February 6, 2018

Autonomy in our technology is real! (Photo courtesy Joshua Andrade- Heinlein Forum on Facebook)

I was privileged to be able to witness the live cast of the Falcon Heavy Lift vehicle today. The photo above shows two booster engine modules simultaneously and autonomously landing. This was just a small part of the technology displayed today by the Falcon Heavy launch.

But here is why I say that a new era starts today:

  1. This is proof that Autonomy in our technology is real. It’s no longer about listening to a reporter somewhere talking about autonomous cars on test tracks. We got to see it ourselves today. It works. Now, it’s just a matter of scaling and networking the technology. We’ll be seeing this in our customers products sooner than we expected.
  2. Private enterprise for the win. NASA’s Bill Gerstenmaier, Associate Administrator for Human Exploration and Operations said that “the NASA SLS (Space Launch System) heavy rocket would cost about $1 billion per launch.” The Falcon Heavy cost is about $90 million per Launch. That’s about $910,000,000 in unneeded taxes per launch.
  3. Today’s launch has proven that the existential joy of engineering is alive and well and making cost effective technology in private enterprise. Space is no longer limited to staid, bureaucratic, rationalizations that it is for research for the common good missions. Today, it is about the human spirit and what we can achieve.
  4. This was not cobbled together by the lowest bidder with a bunch of imported parts. Although the label on a circuit board proudly proclaims “*Made on Earth by humans” this is validation of the capability of US private enterprise, engineering, and the entrepreneurial equivalent of  the gold record on Voyager.
  5. This is the defining event of the new renaissance of Engineering, Entrpreneurialism, and Manufacturing to further mankind’s material progress.  Through our own capable efforts.

Made on Earth by humans (Photo courtesy Joshua Andrade)

I am glad to be a witness to this milestone in the renaissance of manufacturing, engineering, and entrepreneurial accomplishment here in America today.  An electric car, is on its way to Mars. I watched two booster engines land themselves simultaneously. I watched the joy of the engineers as their work accomplished its demonstration of the power of our technology. This is the current generation’s SPUTNIK moment.

Baby boomers can just barely remember what Sputnik did  to transform for our culture, but many of us chose science and engineering and technology careers.  Today, we all had the chance to see a similar watershed for technology, manufacturing, and entrepreneurial spirit, and that it is cool again.

Existential Joy of Engineering- Why shouldn’t we love what we do?

The existential joy of engineering is alive and well, and it has just sent a red car hurtling towards a rendezvous with the red planet.

Red car to rendezvous with a red planet

 

…to be continued

Link to video Space X Falcon Heavy Launch– start at 4:14:24 to start with the launch

Photocredits: for Landing and Circuit board: Joshua Andrade (J Meauho Andrade on Facebook)


Foaming- Why Base Oil Differences Matter In Your Shop.

November 6, 2017

You don’t need a degree in Organic Chemistry to understand the differences in your shops’ metalcutting fluid base oils and what they mean to you.

Synthetic base oils clearly are less prone to foaming than mineral oil base stocks.

A recent discussion on PMPA’s member’s only Technical Listserve centered around the issue of foaming in our machines and its relation to the type of cutting oil selected for use in our CNC and Swiss machines.

John Wiley, Business Development Manager for PMPA Technical Member Qualichem, Inc. contributed a nice piece of sensemaking regarding the role that the selection of base oil plays in the foaming we encounter on the machine.

“In this picture you can clearly see the differences in a base oil’s tendency to foam.  These are pure base oils, nothing added.  Poly Alpha Olefin (PAO) and Gas To Liquid (GTL) synthetics are  identical, while the two mineral oils foam considerably more than the synthetic stocks.  If you are a shop that has yet to experiment with new cutting oil technology, now is the time.  The benefits are firmly within your budgets. If you are doing medical work, the GTL oils are ideal.  If you are running lights out operations, the GTL are ideal.  If you want a cleaner shop, cleaner machines and cleaner parts, GTL is ideal.”

John went on to describe the scenarios where PAO’s and GTL’s would be expected to be the best choice for certain operations (like high pressure pumps) and applications, as well as compared the economics of  PAO’s and GTL’s. Our members got actionable insight as to the effects of the base oil in their metalcutting fluids in terms of both performance and economics.

You may not know a lot about Organic Chemistry, but the photo above is worth a semester in class (as well as a thousand words!) to show us why now is the time to consider Synthetic base oils in our CNC and High Pressure coolant metalcutting operations.

Qualichem,Inc.


Top Ten OSHA Violations in 2017

October 4, 2017

Deputy Director  of OSHA’s Directorate of Enforcement Programs Patrick Kapust presented the agency’s preliminary list at the National Safety Congress and Expo on September 26.

Powered Industrial trucks 1910.178 makes the TOP TEN again in 2017

Here are the Top Ten, along with the number of citations.

  1. Fall Protection – General Requirements (1926.501) – 6,072
  2. Hazard Communication (1910.1200) – 4,176
  3. Scaffolding (1926.451) – 3,288
  4. Respirator Protection (1910.134) – 3,097
  5. Lockout/Tagout (1910.147) – 2,877
  6. Ladders (1926.1053) – 2,241
  7. Powered Industrial Trucks (1910.178) – 2,162
  8. Machine Guarding (1910.212) – 1,933
  9. Fall Protection – Training Requirements (1926.503) – 1,523
  10. Electrical – Wiring Methods (1910.305) – 1,405

If you are just now reviewing your OSHA training  performance, these standards would be a great place to start.

The  items numbered 1910 are General Industry, those numbered 1926 are Construction.

Photo courtesy Staffing Talk