Despite the recent domestic economic downturn, global demand for steel, other metals and heavy equipment continues to increase in emerging markets and elsewhere. With the increasing demand for production, a potential source of personal injury that is often overlooked is quality control testing. Manufacturers face pressures to produce, poor communication with and between workers, and what can sometimes be decades-old equipment. This equipment has usually been continuously retrofitted and appears to function perfectly well, but that is not always the case and serious injury can occur during secondary procedures.
For example, Scott Brooksby defended a steel mill against the claim of a temporary worker who was subject to injury when he was struck in the head by a tail sample cut during sample burning operations. During steel production, tail samples are typically cut from sheet steel. At temperatures approaching 1300 degrees, the tails, which vary in size, are routed on a conveyor system into a sample burning room so that samples can be taken for routing to the laboratory to conduct tensile, radiographic and other quality control tests. The conveyor system is a series of metal rollers controlled by a series of steel gates that regulate the tail samples so that they do not collide and cartwheel into the air or fall from the conveyor, posing a danger to workers.
In Scott Brooksby’s case, a steel tail approximately 8 feet long and 1.5 inches thick was cut from a sheet in the main production roller room. At approximately 1350 degrees Fahrenheit, the sample, which approached 500 pounds, was routed into the sample burner room. Sample burning and many other quality control processes may take place in smaller rooms adjacent to the main production halls. The sample tail is diverted from the main hall after being cut from sheet steel via a steel roller conveyor system where it would pass through a series of gates controlled either electronically or by a set of foot or hand pedals. By the time the eight foot sample reaches the penultimate steel gate it has cooled to approximately 1,000 degrees. Theoretically, after passage through the final gate, the section is cut into smaller lengths, approximately 18-21 inches long, which can be used to stretch and test tensile strength or other quality control issues.
On this particular day, the final gate, at the sample burner itself (which is a laser torch used to cut the 18-21 inch tails), jammed shut just as the penultimate gate opened, allowing the eight-foot section to roll down the conveyor. The section collided with the sample still clutched by the final sample burner gate and cartwheeled into the air, striking one of the two operators in the head and causing injury before falling and smashing the electronic control system. The injured worker’s co-worker was able to deactivate further sample conveyance through use of a retrofitted electronic emergency estop. The steel mill processed approximately 30,000 samples per year and the age of the conveyor system was unknown, but believed to be in excess of 40 years old.
Such cases can be important reminders that the original testing equipment may function perfectly well, but may be retrofitted with any number of safety devices. It is critical that the documentation, if available on older machinery, be preserved and that any maintenance records, including the addition of such safety features as light curtains (which did not exist at the time older, but still functional equipment was manufactured). If a steel or metal mill, foundry, or component manufacturer is operating older equipment, it may be prudent to do a safety engineering study on machinery such as sample burners that exist in virtually every steel mill to determine whether retrofitting available safety devices is an option. For example, with the conventional sample burning conveyor system, it may be that the equipment is custom designed and custom safety add-ons such as horizontal spacers can be welded or bolted across the top of the conveyor at sufficient intervals so that the potential for a sample tail to cart wheel off the conveyor becomes impossible because any vertical force is arrested inches above the conveyor rollers.
If manufacturers have questions about the adequacy of the retrofitting of safety devices on older equipment, they should consider contacting the workplace safety regulatory agency in their state. In some states, OSHA will work with companies and may even provide free safety audits during which the party requesting the audit is granted a period of immunity to correct safety violations that are discovered. Manufacturers should check with their state safety agencies to determine whether such programs are available and should be sure to determine whether immunity from citation is provided in exchange for the voluntary request for inspection.
The additional safety precautions are particularly important in quality control test facilities such as the sample burning room where often less-experienced workers, or temporary workers who may not be sufficiently trained or conscious of the dangers, begin work.
Recall also that any such serious injury must generally be reported to OSHA immediately and certainly within 24 hours. In such cases OSHA investigators may also appear at the premises unannounced and, in most states, there is no right to have counsel present when OSHA is conducting its initial interviews with employees, so management should consider a plan for unplanned requests for interviews from safety investigators and ensure that employees are instructed in advance to focus on only what they actually saw, heard, or said during such interviews.