Forging machine safety requirements

Yes — employers must control lead hazards by temperature control, ventilation, and personal protective equipment. Provide thermostatic controls to prevent overheating as required in 1910.218(a)(1)(i), exhaust permanent lead pot installations per 1910.218(a)(1)(ii), use portable units only in rooms with good general ventilation as in 1910.218(a)(1)(iii), and require workers to wear gloves, goggles, aprons, and other PPE under 1910.218(a)(1)(iv).

• Provide a covered container for dross skimmings (1910.218(a)(1)(v)).
• Keep equipment clean and remove accumulations of yellow lead oxide (1910.218(a)(1)(vi)).

Cite: 1910.218(a)(1).

Inspection records must show the inspection date, the inspector's signature, and the forging machine identifier. Specifically, 1910.218(a)(2)(i) requires certification records that include the date of inspection, the signature of the person who performed the inspection, and the serial number or other identifier of the forging machine inspected.

• Keep these certification records available as part of your maintenance documentation for each machine.

Cite: 1910.218(a)(2)(i).

Guards and point-of-operation protection devices must be inspected at frequent, regular intervals and the inspections must be certified with date, inspector's signature, and equipment identifier. 1910.218(a)(2)(ii) requires scheduling and recording inspections at frequent and regular intervals, and that the recording be a certification record including the date, signature, and serial number or identifier of the equipment inspected.

• "Frequent and regular" is not numerically defined here, so set an interval based on machine use, risk, and manufacturer recommendations and document that schedule.

Cite: 1910.218(a)(2)(ii).

Employers must train personnel who perform the inspections and maintenance so they can do them properly and safely. 1910.218(a)(2)(iii) states that employers are responsible for training personnel for the proper inspection and maintenance of forging machinery and equipment.

• Training should cover what to inspect, how to document results, and how to recognize unsafe conditions.

Cite: 1910.218(a)(2)(iii).

Employers must fasten or protect all overhead parts so they will not fly off or fall if they fail. 1910.218(a)(2)(iv) requires that all overhead parts be fastened or protected to prevent them from flying off or falling in the event of failure.

• Examples: secure bolts with proper locking devices, install guards or catch systems, and inspect fastenings regularly.

Cite: 1910.218(a)(2)(iv).

Hammers and presses must be positioned or anchored to foundations sufficient to support them under applicable engineering standards. 1910.218(a)(3)(i) requires hammers to remain on or be anchored to adequate foundations, and 1910.218(a)(3)(ii) requires the same for presses.

• Use engineering specifications or manufacturer guidance to select and verify foundations.

Cite: 1910.218(a)(3)(i) and 1910.218(a)(3)(ii).

You must disconnect and lock out the power and render cycling controls inoperable, and block the ram or flywheel as required before working on the machine. 1910.218(a)(3)(iii) requires means to disconnect power and lock out or render cycling controls inoperable, while 1910.218(f)(1) specifies that the power be locked out and the flywheel at rest when dies are changed or maintenance is performed on presses; 1910.218(f)(1)(iii) also requires blocking the ram with material meeting Table O-11 specs.

• If testing or repositioning requires temporary re-energization, follow the precautions and sequence in OSHA's lockout/tagout guidance (see OSHA letter of interpretation on the minor servicing exception) to protect employees during that temporary energized condition: https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

Cite: 1910.218(a)(3)(iii) and 1910.218(f)(1) and OSHA letter of interpretation https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

The ram must be blocked with blocks or wedges whose strength and construction meet or exceed the specifications and dimensions shown in Table O-11. 1910.218(a)(3)(iv) mandates blocking and Table O-11 lists timber sizes, crushing strength, and maximum loads the blocks must meet.

• Use the timber sizes and maximum static load guidance in Table O-11 to select blocking material appropriate for the hammer weight and ram dimensions.

Cite: 1910.218(a)(3)(iv).

Tongs must be long enough to clear the worker's body in case of kickback and must not have sharp handle ends. 1910.218(a)(3)(v) requires these features for hammers, and 1910.218(h)(4) repeats the requirement for upsetters.

• Inspect tongs for damage and maintain non-slip grips where appropriate.

Cite: 1910.218(a)(3)(v) and 1910.218(h)(4).

Such devices must be long enough so a worker can reach the full length of the die without placing their hand or arm between the dies. 1910.218(a)(3)(vi) requires these devices to be long enough to allow safe operation from outside the point of operation.

• Provide and train on appropriate tools to prevent exposing hands to crushing or impact hazards.

Cite: 1910.218(a)(3)(vi).

A substantial scale guard must be provided at the back of every hammer and every press and arranged to stop flying scale. 1910.218(a)(3)(viii) and 1910.218(a)(3)(ix) require these guards.

• Ensure guards are of robust construction and are inspected and maintained as part of your regular guard inspection program.

Cite: 1910.218(a)(3)(viii) and 1910.218(a)(3)(ix).

Die keys and shims must be made from a grade of material that will not unduly crack or splinter. 1910.218(b)(1) requires selecting materials for keys and shims that avoid cracking or splintering during use.

• Choose materials consistent with manufacturer recommendations and inspect for damage before use.

Cite: 1910.218(b)(1).

All foot-operated devices must be substantially and effectively protected from unintended operation. 1910.218(b)(2) requires that treadles, pedals, bars, valves, and switches be guarded to prevent accidental activation.

• Use shields, covers, or interlocks to prevent accidental actuation and inspect guards regularly.

Cite: 1910.218(b)(2).

All manually operated valves and switches must be clearly identified and readily accessible. 1910.218(c) requires labeling and accessibility so operators can quickly find and operate controls.

• Use durable labels and maintain clear access paths to controls; include this in training and inspection checklists.

Cite: 1910.218(c).

Steam and air hammers must have a safety cylinder head to cushion if the rod breaks, a quick-closing emergency valve that can be closed and locked out, and means for cylinder draining. 1910.218(d)(1) requires a safety cylinder head, 1910.218(d)(2) requires a quick-closing emergency valve to be closed and locked during adjustments or die changes, and 1910.218(d)(3) requires a means of cylinder draining (self-draining or quick-acting drain cock).

• Ensure these features are present, functional, and included in your inspection records.

Cite: 1910.218(d)(1), 1910.218(d)(2), and 1910.218(d)(3).

Steam or air piping for forging hammers must conform to ANSI B31.1.0-1967 (Power Piping) as incorporated by reference in [1910.6]. The forging standard states steam or air piping must conform to the specifications of American National Standard ANSI B31.1.0-1967, and that incorporation is effected under [1910.6] as referenced in 1910.218(d).

• Use qualified piping materials and inspections consistent with ANSI B31.1 and document compliance in maintenance records.

Cite: 1910.218(d) and 1910.6.

Air-lift hammers must have a safety cylinder head, an air shutoff valve, two drain cocks (one on the main head cylinder and one on the clamp cylinder), and air piping that conforms to ANSI B31.1.0-1967. These requirements are listed in 1910.218(e)(1)(i)-(iv).

• Verify shutoff valves and drain cocks are accessible and locked out when performing maintenance.

Cite: 1910.218(e)(1)(i)-(iv).

Employers must provide a suitable enclosure to prevent damaged or detached boards from falling, and securely fasten the board enclosure to the hammer; they must also ensure all major assemblies and fittings that can loosen and fall are properly secured. 1910.218(e)(2)(i)-(ii).

• Inspect fastenings before operation and after any maintenance; secure loose parts immediately.

Cite: 1910.218(e)(2)(i)-(ii).

For mechanical presses, the power must be locked out, the flywheel at rest, and the ram blocked with material meeting Table O-11; for hydraulic presses, the hydraulic pumps and power apparatus must be locked out and the ram blocked per Table O-11. 1910.218(f)(1)(i)-(iii) and 1910.218(f)(2)(i)-(ii) specify these steps.

• Follow LOTO procedures and maintain lockout documentation and blocking verification before work begins.

Cite: 1910.218(f)(1) and 1910.218(f)(2).

Hot trimming presses must follow the same lockout and blocking requirements as presses under [1910.218(f)(1)], while cold trimming presses must be safeguarded in accordance with [1910.217(c)]. 1910.218(g)(1) applies the press safety steps to hot trimming presses, and 1910.218(g)(2) points to 1910.217(c) for cold trimming press safeguarding.

• For cold trimming, follow the point-of-operation and safeguarding rules in 1910.217(c).

Cite: 1910.218(g)(1), 1910.218(g)(2), and 1910.217(c).

Upsetters must be installed so they remain on their supporting foundations, provided with a means for locking out power at its entry point and rendering cycling controls inoperable, and manually operated controls must be clearly identified and accessible. 1910.218(h)(1)-(3)–(3) set these rules; 1910.218(i)(1)-(2) apply these upsetter provisions to boltheading and rivet making.

• Lockout procedures must be used when changing dies, performing maintenance, or any work on the machine per 1910.218(h)(5).

Cite: 1910.218(h)(1)-(5) and 1910.218(i)(1)-(2).

Billet shears must have a positive-type lockout device for disconnecting power, and saws must have a guard of not less than one-eighth inch sheet metal positioned to stop flying sparks. 1910.218(j)(1) and 1910.218(j)(2) set these requirements.

• Lockout devices must allow positive isolation; saw guards should be robust and checked before operation.

Cite: 1910.218(j)(1) and 1910.218(j)(2).

Conveyor power transmission equipment must be guarded in accordance with ANSI B20.1-1957, which is incorporated by reference as specified in [1910.6]. 1910.218(j)(3) requires guarding per ANSI B20.1-1957.

• Use guards that prevent access to moving parts and follow the referenced ANSI standard for design and inspection guidance.

Cite: 1910.218(j)(3) and 1910.6.

If temporary energization is necessary for testing or positioning during setup, the employer may re-energize only after following the required sequence to protect employees and must reapply lockout/tagout when testing is finished. OSHA's lockout/tagout interpretation explains the limited re-energization steps and protections required for testing or positioning under 1910.147(f)(1) (see OSHA letter of interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21). This complements 1910.218(a)(2) and press-specific lockout rules in 1910.218(f).

• Required sequence per the interpretation includes clearing tools/materials, removing employees from hazard areas, removing LOTO devices as specified, energizing for testing with employee protections in place, then de-energizing and reapplying LOTO if further servicing is needed.

Cite: OSHA letter of interpretation https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21; 1910.218(f).

Shot blast cleaning chambers must have doors or guards to protect operators, and grinding operations must be safeguarded as specified in the standard. 1910.218(j)(4) requires protective doors or guards on cleaning chambers and 1910.218(j)(5) addresses grinding (expect requirements for proper guards, eye protection, and maintenance).

• Ensure doors/guards interlock or otherwise prevent operator exposure to blasting media; maintain grinder guards, tool rests, and PPE.

Cite: 1910.218(j)(4) and 1910.218(j)(5).

The employer is responsible for maintaining all forge shop equipment in a condition that ensures continued safe operation. 1910.218(a)(2) makes maintenance the employer's responsibility and lists the inspection, scheduling, training, and fastening duties that help meet that obligation.

• Implement written maintenance schedules, certification records, trained maintenance staff, and documented inspections to demonstrate compliance.

Cite: 1910.218(a)(2).