Case Study 1: Printing Press Roll Cleaning

Incorrect.  In this case, the employer is not correct.

The minor servicing exception does not apply. Even though the roll cleaning activity takes place during normal production operations and is routine, repetitive, and integral to the production operation, the employer has not implemented alternative measures which provide effective protection from the ingoing nip points of the press rolls. Employees instead are required to bypass a machine guard, which is required by Subpart O of 29 CFR 1910, and place their hands and cleaning rags into the press's danger zone. In the absence of alternative protective measures, this cleaning task is a servicing or maintenance activity that is covered by 1910.147.

In summary, for the minor servicing exception to apply, each and every element of the exception must be met. In this case, the work is not being performed using alternative measures that provide effective employee protection.

For more information: Read the September 16, 1992, letter of interpretation to Mr. John Runyan of the Printing Industries of America, Inc., for details on how to use safe alternative measures for printing presses.

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