Baking & Snack - July 2016 - 102

INDUSTRY INSIGHT

"Far too often, LOTO
control aspects are
overshadowed by the
procedures themselves."
adding ingredients, scraping the bowl, checking dough
for consistency)."
The memorandum went on to state, "Safeguarding
a worker from potential exposure to the machinery
hazard(s) of a mixer must be provided by a barrier guard
or a safeguarding device. When safeguarding by barrier
guard or a device is not feasible, safeguarding by maintaining a safe distance may be used. An employer who
adopts a work practice of 'safe distance' protection must
be prepared to demonstrate an effective work practice
to OSHA. An employer can meet this obligation by establishing and having employees follow a work practice
which includes exposure prevention procedures, training and enforcement ... Work practices, however, are
not to be used in lieu of necessary machine guarding
when guarding is feasible."
Ovens, 29 CFR 1910.263(l)
... (1)(vii) Ovens shall be located so that possible fire
or explosion will not expose groups of persons to possible injury. For this reason, ovens shall not adjoin lockers, lunch or sales rooms, main passageways or exits.

... (9)(ii) All safety devices on ovens shall be inspected at intervals of not less than twice a month by an especially appointed, properly instructed bakery employee
and not less than once a year by representatives of the
oven manufacturers.
A 1989 letter of clarification written by OSHA's
Directorate of Compliance Programs (DCP) stated that
OSHA interprets "Safety Devices" as fail-safe devices
and as components of safety control systems installed
to ensure that explosions or explosive conditions do not
develop within an oven. Safety devices are installed to
automatically shut down the oven in a safe manner in
the event of an occurrence of a hazardous condition.
In 1998, DCP also stated that for annual oven inspections, OSHA considers "representatives of the oven
manufacturer" to be qualified persons who are knowledgeable of the various safety considerations and of the
safe operational characteristics of the equipment. They
may or may not be employees of the oven manufacturer.
This position was reaffirmed by OSHA in 2001.
Keep in mind that OSHA compliance is a major issue
that cannot be fully addressed in this primer series. If
you feel I've missed something vital here or have suggestions as we look forward to Food Safety Modernization
Act compliance in the next primer, please reach out to
me. As I mentioned in the previous column, this is important for us all.

Editor's note: Readers can find the first of Mr. Kline's regulatory primers, "Something Old, Something New," in May
2016 Baking & Snack, Page 99.

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Baking & Snack - July 2016

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