• Secondary safeguarding methods give extra protection by supplementing primary safeguards.
• Employers may never use secondary safeguarding methods alone unless primary safeguarding is impossible.

Safeguarding methods that offer some protection but do not prevent employees from reaching into the die area are considered secondary safeguarding methods. Examples of secondary safeguarding include:

• Presence-sensing devices,
• Awareness devices, and
• Safe work procedures.

Employers may use secondary safeguarding methods to supplement primary safeguarding methods for protecting employees against the hazards of mechanical power presses. However, employers are prohibited from using secondary safeguarding methods alone unless they can show that it is impossible to use any of the primary safeguarding methods.

The following are some work practices, complementary equipment, and energy control procedures that should supplement primary safeguarding methods.

“No-hands-in-die” policy and hand-feeding tools

Employers need to enforce a “no-hands-in-die” policy that prohibits power press operators from placing hands in the die area during normal operations, unless a press is designed for “hands-in-die” work. Employers must also enforce the use of hand tools to feed and remove material from the die area to minimize the time operators’ hands spend near it, even when hand feeding is allowed according to 29 CFR 1910.217(d)(1)(ii).

However, hand-tool feeding alone does not ensure that the operator’s hands cannot reach the danger area. For this reason, employers must still use primary safeguarding methods to protect operators, such as secure barrier guards and a properly applied two-hand control or two-hand trip safeguarding device.

Integrating point-of-operation safeguarding with lockout/tagout

When guards are removed from the die area for press servicing and maintenance work such as die setting and repair, exposure to hazardous slide motion creates serious point-of-operation hazards. Employees performing this kind of servicing and maintenance must use energy control procedures that integrate point-of-operation safeguarding methods with lockout/tagout procedures.

One essential point-of-operation safeguarding method is the safe use of an inch or jog safety device. By operating a part-revolution press in the inch mode, using two-hand controls or a single control mounted at a safe distance from the die area, die setters and service personnel can control hazardous slide motion by gradually “inching” the press through small portions of a stroke.

However, an inch or jog safety device cannot prevent the slide from falling if there is a component or control system malfunction or if the press is activated by others. For this reason, additional energy control precautions (e.g., safety blocks; lockout/tagout of the press disconnect switch if re-energization presents a hazard) are necessary if employees must place hands or arms between a press’s bolster plate and slide for servicing and maintenance such as adjusting, cleaning, or repairing dies.