An Ohio subsidiary of one of the world’s largest automotive suppliers could have prevented a 26-year-old employee in Franklin from being fatally crushed in October 2023 if the company had provided proper machine guarding. OSHA responded after being informed of the incident and learned the worker, on the job for about a year, was placing cardboard under a machine that bends vehicle exhaust pipes when the incident happened.
OSHA issued 10 instance-by-instance citations after finding the company did not properly train employees — including temporary workers under the company’s control — in lockout/tagout procedures.
OSHA also issued a machine guarding violation. Investigators determined the employer failed to include detailed steps for lockout/tagout procedures, test its safety procedures annually and guard machines adequately.
Based on these alleged violations, the company exposed machine operators to struck-by and caught-between hazards.
In 2022, the agency cited the company for similar violations at the same location.
The company faces $314,555 in proposed OSHA penalties for its recent infractions.
Citation 1 Item 1
Type of Violation: Serious; $16,131
29 CFR 191O.147(c)(6)(i): The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.
(A) The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.
(B) The periodic inspection shall be conducted to correct any deviations or inadequacies identified.
(C) Where lockout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected.
a) On or about October 14, 2023, the employer did not conduct periodic inspections for each energy control procedures at least annually for equipment such as benders, sizers, and presses.
Citation 1 Item 2
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 13, 2023, Set-up technician #1I was not trained as an authorized employee for the proper use of energy control procedures, how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic for equipment including benders and sizers prior to performing servicing and maintenance tasks such as but not limited to changing wipers on benders, changing blades on benders, changing mandrel cables benders, tooling changeovers on benders, and adjustments on sizers.
On October 26, 2023, Set-up Technician #11 was performing a changeover on Bender 26 and only isolated the electrical power to the machine, leaving the pneumatic source pressurized, thereby not following the energy control procedure for safe control of hazardous energy.
Citation 1 Item 3
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 12, 2023, Set-up technician #24 was not trained as an authorized employee for the proper use of energy control procedures and how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic energy sources for equipment including but not limited to benders, sizers, and cut offs prior to performing servicing or maintenance activities such as but not limited to setting up collets blocks (guides on benders), changing wipers on benders, changing blades on benders, changing mandrel cables on and performing bender tooling changeovers on benders.
Citation 1 Item 4
Type of Violation: Serious; $16,131
29 CFR 191O.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 12, 2023, Set-up technician #25 was not trained as an authorized employee for the proper use of energy control procedures and how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic energy sources for equipment including but not limited to benders, sizers, and cut offs prior to performing servicing or maintenance activities such as but not limited to setting up collets blocks (guides on benders), changing wipers on benders, changing blades on benders, changing mandrel cables on and performing bender tooling changeovers on benders.
Citation 1 Item 5
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 12, 2023, Set-up technician #21 was not trained as an authorized employee for the proper use of energy control procedures and how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic energy sources for equipment including but not limited to benders, sizers, and cut offs prior to performing servicing or maintenance activities such as but not limited to setting up collets blocks (guides on benders), changing wipers on benders, changing blades on benders, changing mandrel cables on and performing bender tooling changeovers on benders.
Citation 1 Item 6
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 13, 2023, bender operator #3 was not trained as an authorized employee in the recognition of applicable hazardous energy sources, methods and means necessary for energy isolation and control prior to changing wipers, blades and clamps, and TPM servicing and maintenance on equipment to include handfed benders.
Citation 1 Item 7
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 13, 2023, bender operator #4 was not trained as an authorized employee in the recognition of applicable hazardous energy sources, methods and means necessary for energy isolation and control prior to changing wipers, blades and clamps, and TPM servicing and maintenance on equipment to include handfed benders.
Citation 1 Item 8
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 13, 2023, Bender Operator #10 was not trained as an authorized employee for the proper use of energy control procedures and how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic energy sources for equipment including but not limited to benders prior to performing servicing or maintenance activities such as but not limited to changing wipers on benders, changing blades on benders, and performing daily cleaning of benders.
Citation 1 Item 9
Type of Violation: Serious; $16,131
29 CFR 191O.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy contrnl program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 13, 2023, Gap Leader #13 was not trained as an authorized employee for the proper use of energy control procedures and how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic energy sources for equipment including but not limited to benders prior to performing servicing or maintenance activities such as but not limited to changing wipers on benders, changing blades on benders, and performing daily TPM cleaning and maintenance.
Citation 1 Item 10
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessaiy for energy isolation and control.
a) On or about October 13, 2023, Gap Leader #7 was not trained as an authorized employee for the proper use of energy control procedures and how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic energy sources for equipment including but not limited to benders prior to performing servicing or maintenance activities such as but not limited to changing wipers on benders, changing blades on benders, and performing daily TPM cleaning and maintenance.
Citation 1 Item 11
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(i)(A): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:
(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
a) On or about October 13, 2023, Gap Leader #23 was not trained as an authorized employee for the proper use of energy control procedures and how to safely shutdown machines and when to isolate energy sources such as electric, pneumatic and hydraulic energy sources for equipment including but not limited to benders prior to performing servicing or maintenance activities such as but not limited to changing wipers on benders, changing blades on benders, and performing daily TPM cleaning and maintenance.
Citation 1 Item 12
Type of Violation: Serious; $16,131
29 CFR 1910.147(c)(7)(iii)(A): Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures.
a) On or about October 14, 2023, employees did not receive retraining after maintenance technicians performing service and maintenance tasks deviated from the energy control procedures for benders. Maintenance technicians locked E-stops and interlocked doors for cells versus following the documented machine specific lockout procedures.
Citation 1 Item 13
Type of Violation: Serious; $16,131
29 CFR 191O.147(d):Application of control. The established procedures for the application of energy control (the lockout or tagout procedures) shall cover the following elements and actions and shall be done in the following sequence:
(d)(1) Preparation for shutdown. Before an authorized or affected employee turns off a machine or equipment, the authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy.
(d)(2) Machine or equipment shutdown. The machine or equipment shall be turned off or shut down using the procedures established for the machine or equipment. An orderly shutdown must be utilized to avoid any additional or increased hazard(s) to employees as a result of the equipment stoppage.
(d)(3) Machine or equipment isolation. All energy isolating devices that are needed to control the energy to the machine or equipment shall be physically located and operated in such a manner as to isolate the machine or equipment from the energy source(s).
(d)(4) Lockout or tagout device application.
(d)(4)(i) Lockout or tagout devices shall be affixed to each energy isolating device by authorized employees.
(d)(4)(ii) Lockout devices, where used, shall be affixed in a manner to that will hold the energy isolating devices in a "safe11 or 11of f1' position.
(d)(5) Stored energy.
(d)(5)(i) Following the application oflockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe.
(d)(5)(ii) If there is a possibility ofreaccumulation of stored energy to a hazardous level, verification of isolation shall be continued until the servicing or maintenance is completed, or until the possibility of such accumulation no longer exists.
(d)(6) Verification of isolation. Prior to starting work on machines or equipment that have been locked out or tagged out, the authorized employee shall verify that isolation and deenergization of the machine or equipment have been accomplished.
a) On or about October 12, 2023, employees were exposed to machine hazards associated with moving parts during changeovers, wiper die changes, clamp changes, blade changes, TPMs, and the cleaning of benders. The employer did not ensure employees implemented energy control application steps (d)(l) through (d)(6) prior to conducting servicing and maintenance on equipment.
Citation 1 Item 14
Type of Violation: Serious; $16,131
29 CFR 1910.212(a)(1): Types of guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating paiis, flying chips and sparks. Examples of guarding methods are-barrier guards, two hand tripping devices, electronic safety devices, etc.
a) On or about October 14, 2023, located in the Bending Area, employees operated an Addition Manufacturing handfed Bender #31 that was not guarded to protect the employees from moving parts of the bender exposing the employees to caught-between and struck-by hazards. On October 14, 2023, Employee #1 was placing cardboard on the floor under Bender #31 which was an area that was not being detected by a Keyence Safety Laser Scanner. The bender was restarted by another employee causing the bend arm to close on Employee #I resulting in death.
b) On or about October 14, 2023, located in the Bending Area, employees operated an Addition Manufacturing handfed Bender #16 that was not guarded to protect the employee from moving parts of the bender exposing the employees to caught-between and struck-by hazards.
c) On or about October 14, 2023, located in the Bending Area, employees operated an Addition Manufacturing handfed Bender #23 that was not guarded to protect the employees from moving parts of the bender exposing the employees to caught-between and struck-by hazards.
d) On or about October 14, 2023, located in the Bending Area, employees operated an Addition Manufacturing handfed Bender #24 that was not guarded to protect the employees from moving parts of the bender exposing the employees to caught-between and struck-by hazards.
e) On or about October 14, 2023, located in the Bending Area, employees operated an Addition Manufacturing handfed Bender #28 that was not guarded to protect the employees from moving parts of the bender exposing the employees to caught-between and struck-by hazards.
Citation 2 Item 1
Type of Violation: Repeat - Serious; $88,721
29 CFR 1910.147(c)(4)(ii): The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following:
(A) A specific statement of the intended use of the procedure;
(B) Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;
(C) Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and
(D) Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.
a) On or about October 13, 2023, the employer did not ensure that machine specific energy control procedures for benders included the rules for the application of the procedure, the magnitude of hydraulic and pneumatic energy sources, a specific statement of the intended use for each procedure, specific procedural steps for the safe shutdown, specific procedural steps for removal and transfer of locks, and the means to enforce compliance as required by paragraphs (A through D).
Company was previously cited for a violation of its equivalent Occupational Safety and Health standard 1910.147(c)(4)(ii)(B), which was contained in OSHA inspection number 1554291, citation number I, item number 2 and was affirmed as a final order on January 26, 2022, with respect to a workplace located in Franklin, OH 45005.
Citation 3 Item 1
Type of Violation: Other-than-Serious; $0
29 CFR 1910.147(c)(6)(ii): The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection , the employees included in the inspection, and the person performing the inspection.
a) On and before October 14, 2023, the employer did not ensure that the periodic inspections being certified were conducted correctly in that only bender machines in the facility were inspected . The periodic inspections conducted by maintenance employees did not include the energy control procedures being utilized, the dates of was properly certified correctly in that maintenance employees did not conduct the periodic inspection utilizing the energy control procedures for benders, The periodic inspections being conducted did not list what equipment on of all energy control procedures were conducted, and did not certify that the procedures that were completed by authorized employees identified the machine or equipment being inspected.
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