Miller Engineering Services

Guarding & Entanglement Accidents

Background: Early Mechanical Safety
The origins of early safety concerns were in the steam boiler era, the first type of portable power generation. This was power which would explode if not controlled; a small boiler had the capability of destroying an entire structure the size of a city block. This steam power was converted into rotating shaft power, which then found its way into everything from rail locomotives to drill presses, lathes, power presses, and milling machines, etc. The first of the mechanical machine safety standards were for boilers (ASME Standards), then power transmission (steam belt power), then, probably, machine guarding (power presses). Boiler safety was brought under control through these standards, as the newly required designs and controls were successful in controlling boiler explosion accidents. However, power transmission and machine guarding were more difficult since they involve diverse mechanical safety hazards, a multitude of employees using such machines, and thousands of types of machinery, each having its safety guarding challenges.

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Miller Engineering Expertise
Miller Engineering began with Dr. Miller's expertise in mechanical engineering and has strengthened this expertise through other mechanical engineers on the staff. Naturally, this area of mechanical engineering safety has remained one of our specialty areas. From a standards viewpoint, Dr. Miller was a director of safety standards for Federal OSHA and had responsibility for revising all OSHA safety standards relative to all machinery and processing equipment used in manufacturing or construction. This included power transmission, mechanical power presses, general machine guarding, elevated work platforms and power tools. Consequently, we are extremely familiar with the safe guarding of nearly any type of mechanical device through initial design, redesign or after-market applications. We fully subscribe to the "Principles of Guarding." These principles include: Designing out any hazard in the machine or process, if possible and feasible; Guarding those hazards which cannot be designed out, providing the function of the machine is not destroyed; Instructing persons operating or around such machinery of the hazards involved; and/or Warning of hazards which cannot be passively protected by design or guarding. Through our publications and projects, we have preached and practiced these Principles of Guarding.
Example Projects include:
Guard designs for wire terminating machines
Total Machine enclosures to guard and provide noise protection
Power Take-off (PTO) shaft guarding
Power transmission shaft entanglement accidents
Interpretation/Application of OSHA Table O-10 guarding criteria
Mechanical Safety of off-shore oil rig operations
Nail guns, mitre saws, radial saws guarding/accidents

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Example Publications include:
  • Miller, J.M. (1982). The Management of Occupational Engineering. In the Handbook of Industrial Engineering. John Wiley.
  • Miller, J.M. and Barrett, T. (1980). "Memorandum of Understanding [U.S. Coast Guard and U.S. Department of Labor (OSHA)] : Occupational Safety and Health on Artificial Island, Installations and other Devices on the outer Continental Shelf of the United States." Federal Register, 45(29).
  • Miller, J.M. and Bingham, E. (1979). "Response to Advanced Notice of Proposed Rule Making on Unregulated Hazards on the Outer Continental Shelf." Federal Register, September 20, Docket CG79-073.
  • Miller, J.M. (1979, February). "Verticalization Package of OSHA 1910/1926 Safety and Health Standards." Federal Register.
  • Miller, J.M. and Bingham, E. (1978, February). "What's Ahead for OSHA Standards," Invited paper for the Greater New York Safety Council and the New Jersey Chamber of Commerce, New York.
  • Miller, J.M. and Bingham, E. (1977, October). "Priorities for Future OSHA Standards Activities." Invited paper by the National Safety Council for the National Safety Congress, Chicago.
  • Robots and Highly Automated Machinery Section(under construction)

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