At an employer's automotive component manufacturing facility, manufacturing operations make extensive use of robots located within fenced cages. At one location, suspension parts are transferred by rotating tables from station to station while greasing and other operations are performed on the parts by robots. If necessary, employees can gain access to the robots by entering the cages through electrically interlocked gates. When the gates are opened, the multiple energy sources that power the robots, rotating tables, and related machinery are turned off but are not deenergized or locked out. An employee who is inside a cage when a robot is activated could be struck by the robot arm or other machine parts and seriously injured.
An injury occurred when an employee, consistent with the employer's practices, entered the robot cage without deenergizing or locking out any equipment. The employee was attempting to unjam a robot arm. In freeing the arm, the employee tripped an electric eye, causing the robot arm to cycle. The employee's arm was struck by the robot and injected with grease. The employer contends that Lockout Procedures were not necessary because once the gate is opened, movement of the robot arm is impossible, and a Maintenance worker inside the cage would have ample warning - by the closing of the interlocked gate - before the machinery started up, to avoid injury. According to the employer, once the interlocked gate is opened, it must first be closed and a number of buttons must be pushed before any machine movement can occur. The startup procedure would take some time and the person inside the robot area would be aware of the closing of the gate and the presence of another worker at the nearby control panel.
Does the unjamming operation take place during normal production operations?
Would the minor Servicing exception apply to this situation?
Was the activity performed by the employee covered by the Lockout/Tagout standard?
In this situation, would the interlocked gate alone satisfy the employer's Lockout/Tagout obligations?
The employer contends that deenergizing and locking out a robot wipes out the robot's memory and requires time-consuming reprogramming. Based on this alone, could the employer claim that shutting down the robot was impractical and thus, claim that the unjamming task was exempted?
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