Miles Free

As Director of Technology and Industry Research for PMPA, Miles brings 38 years of hands-on experience in areas of manufacturing, quality and steelmaking. He helps answer "HOW?","WITH WHAT?" and "REALLY?"

Posted by: Miles Free 28. October 2014

OSHA Top 10 Violations from 2013


I would add “grinders” to my personal walk-around inspection list. 


OSHA recently posted its top 10 most frequently cited violations for the fiscal year 2013. While two of the top three are construction industries, the balance are general industry and general requirements applicable to our shops.

Fall protection, construction (29 CFR 1926.501

Hazard communication standard, general industry (29 CFR 1910.1200

Scaffolding, general requirements, construction (29 CFR 1926.451

Respiratory protection, general industry (29 CFR 1910.134)

Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305

Powered industrial trucks, general industry (29 CFR 1910.178)

Ladders, construction (29 CFR 1926.1053

Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147

Electrical systems design, general requirements, general industry (29 CFR 1910.303

Machinery and Machine Guarding, general requirements (29 CFR 1910.212

Savvy managers will make sure that their safety training plans cover the general industry and general requirements topics listed here.


Originally posted on blog. 

Posted by: Miles Free 21. October 2014

PMPA Opposes OSHA’s Expanded Workplace Rule


The Precision Machined Products Association (PMPA) filed official comments opposing an administration proposal to place additional burdens on employers while loosening injury reporting requirements on employees.

Clarity, not confusion, should be the work product coming out of here.

On August 14, the U.S. Occupational Safety and Health Administration (OSHA) issued a Supplemental Notice to a pending rule to make injury and illness reports public, which becomes final in March 2015. The notice reframes Employee injury reporting as a “right” rather than a “duty.”

Reporting of injuries and illnesses is not a right. It is an obligation of the employee to report, and a responsibility of the employer to record, investigate, and take appropriate remedial actions to retrain as necessary and to remove any hazards so identified.

“We are very concerned that the as-yet unpublished regulatory text will actually become an obstacle to our ability to manage safety and hazard identification in manufacturing facilities,” says Rob Kiener, PMPA interim executive director. “By changing the understanding of an employee’s “obligation to report injuries and illnesses” to a “right to report,” OSHA allows workers the discretion to not report while maintaining the burden on employers,” Mr. Kiener says.

For these reasons, and the reasons given in our submitted letter, earlier comments, and testimony, the PMPA urged OSHA to withdraw both the proposed regulation and Supplemental Notice.

In the absence of actual regulatory text for us to review, OSHA creates only uncertainty regarding employers’ duties and obligations.

Furthermore, by ignoring OSHA’s own rule that employee compliance is a “duty,” OSHA potentially creates a means for employees to fail to report injuries and illnesses, with the proliferation of unrecognized hazards in workplaces across the country as a probable result.

Originally posted on blog. 

Posted by: Miles Free 14. October 2014

PMPA Member Attracting Talent to Manufacturing

Manufacturing Day event at Bracalente Manufacturing Group. Real People. Real jobs.

PMPA member Bracalente Manufacturing Group held its first MFG Day event recently. Students got to see first-hand what a career in precision machining could look like. The event helped to change the conversation regarding the need for skilled people in advanced manufacturing companies like Bracalente Group.

Bracalente Group’s Trumbauersville, Pennsylvania, event hosted 120 nineth graders, 20 students from the local vocational/technical school, and 90 students from the new STEM program.

The STEM program is a college preparatory class structure for kids who are interested in engineering and technology.

This video highlights the event.

PMPA member companies across the U.S. and Canada joined Bracalente in helping to change the conversation regarding options for satisfying, well paying technical careers. What are you doing to change the conversation?

Originally posted on blog. 

Posted by: Miles Free 7. October 2014

Don’t Burn the Tool

A bit of circa 1965 “Knowledge Retention” from the archives of Lester Detterbeck Enterprises Ltd.

If a tool gets too hot to hold while grinding, you have already ruined it. You knew that, right? By the time the heat gets to your hands and is too hot to hold, you have already lost the temper on the edge being ground. If you then put it in water to cool it down, depending on the material grade, the water quench is likely to help form untempered martensite, a brittle microstructure.

The tool will lose properties and fail in very short order, often with catastrophic consequences. The point of grinding is to take small amounts of removal by abrasion, not to create lots of heat by hogging the material off.

Heat treated tools are actually very sophisticated system involving the interaction of material chemistry, microstructure, mechanical properties (including hardness) and design.

Out of control grinding practices can destroy this system with a single temperature excursion above the tool’s last tempering temperature and formation of untempered martensite by water quenching.

Thanks to John Detterbeck at Lester Detterbeck Enterprises Ltd. for sharing the above cartoon and confirming the failure mode.


This article was originally posted on blog.

Posted by: Miles Free 23. September 2014

OSHA: Requirements Change for Reporting Fatalities and Severe Injuries


Under the revised rule, employers will be required to notify OSHA of work-related fatalities within 8 hours, and work-related in-patient hospitalizations, amputations or losses of an eye within 24 hours. Previously, OSHA’s regulations required an employer to report only work-related fatalities and in-patient hospitalizations of three or more employees. Reporting single hospitalizations, amputations or loss of an eye was not required under the previous rule.

The final rule was announced by OSHA on September 11. The rule also updates the list of employers partially exempt from OSHA recordkeeping requirements.

This new, final rule enters into effect January 1, 2015. Link here to pre-publication text of final rule. After publication, the final rule can be accessed from here or through the Federal Register website.

In a final rule posted in the Federal Register on September 11, OSHA has also updated the list of industries that, because of relatively low occupational injury and illness rates, are exempt from the requirement to routinely keep injury and illness records. The rule will go into effect January 1, 2015, for workplaces under federal OSHA jurisdiction.

Regardless, all employers covered by the Occupational Safety and Health Act, even those who are exempt from maintaining injury and illness records, are required to comply with OSHA’s new severe injury and illness reporting requirements.

OSHA’s web page on the revised rule. 


Originally posted on blog

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