Baking & Snack - July 2016 - 101

INDUSTRY INSIGHT
Jim Kline
jkline@theensolgroup.com

By giving priority
attention to where
most violations occur,
bakers can better
achieve compliance
and avoid fines when ...

coping with

OSHA

Running a bakery means dealing with government regulations. In an effort to help navigate this web, I have
written a series of primers on regulations that wholesale
bakery operations commonly confront. Remember, this
is not a comprehensive guide; it's just a quick reference
that can trigger more considerations and help ensure
standards can be met.
This month, we discuss Occupational Safety and
Health Agency (OSHA) compliance - a phrase that often strikes fear into the hearts of bakery plant operators.
Lockout/tagout (LOTO) is among the Top 10 violations most frequently cited by OSHA not only because
it is one of the most frequently misunderstood standards
but also because of its title, which is designated as 29 CFR
1910.147, "The Control of Hazardous Energy (Lockout/
Tagout)." Far too often, LOTO control aspects are overshadowed by the procedures themselves. The standard
addresses control of all hazardous energies - electrical,
mechanical, hydraulic, pneumatic, chemical, thermal and
other energy sources - and is written specifically to protect employees during service and maintenance.
The standard requires that employers identify and
document all energy sources for their equipment;
develop, implement and enforce an energy control
program; ensure new and "overhauled equipment" is
capable of being locked out; ensure the LOTO devices
identify the individual user; and provide and document
training of all employees covered by the standard.
If you're wondering whether this standard should be
taken seriously, consider that each violation, if found
to present the potential for serious consequence to a
worker, can carry a fine of up to $7,000.
In addition to the general regulations, of which the

"control of hazardous energy" is a part, there are a few
industry-specific regulations that are frequently overlooked or misunderstood. OSHA defines bakery equipment requirements in 29 CFR 1910.263, which is in the
Subpart R listing of "Special Industries." The items in
this subpart are applicable to all bakeries and are not
restricted by size or product. Therefore, the following
items are required of all bakeries.
General Machine Guarding, 29 CFR 1910.263(c)
... (2) All gears shall be completely enclosed regardless of location.
... (3) Sprockets and V-belt drives located within
reach from platforms or passageways or located within
8 ft, 6 in. from the floor shall be completely enclosed.
Horizontal Mixers, 29 CFR 1910.263(e)1
... (v) All mixers with power and manual dumping arrangements shall be equipped with safety devices which shall: (a) Engage both hands of the operator
when the agitator is in motion under power and while
the bowl is opened more than one-fifth of its total opening. (b) Prevent the agitator from being started while the
bowl is more than one-fifth open without engaging both
hands of the operator.
Vertical Mixers, 29 CFR 1910.263(e)(2)(i)
Although this standard does not require a mixing
bowl cover, an OSHA Enforcement memorandum issued Feb. 26, 1999, regarding "Vertical Food Mixers," established that the need for a cover exists if the worker(s)
activities are in proximity to the hazard (rotating part)
and considers how a worker "performs operations (e.g.,

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Baking & Snack - July 2016

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