Creating a Safety Program for 3D Printing Environments
October 2019
1. Introduction
3D printing or additive manufacturing safety is a topic of ongoing research. In this article we cover various standards, guidelines and ongoing research that applies to creating a safety program for 3D printing environments. Then we propose a synthesized approach to creating such a program. The References section provides links to important research papers, guidelines, and standards.
Guidelines and standards have been proposed by a number of agencies:
· OSHA (Occupational Safety and Health Administration)
· UL Chemical Safety
· NIOSH (National Institute for Occupational Safety and Health) under CDC
· NTRS (NIOSH Nanotechnology Research Center)
· NFPA (National Fire Protection Association)
· FDA (Food & Drug Administration)
· Various universities and institutions that run 3D printing labs
In addition to the above, environments like R&D lab settings would have other safety risks arising from the introduction of experimental machinery.
2. Recent Safety Incidents
OSHA reports an explosion and fire at a 3D printing company that resulted in 3rd degree burns to an employee. OSHA cited the 3-D printing firm for exposing workers to combustible metal powder, electrical hazards, and imposed penalties of over $64,000.
The firm failed to eliminate known sources of potential ignition or follow pertinent instructions from equipment manufacturers, and did not alert the County Fire Department to the workplace presence of hazardous materials. Additionally, the firm located an employee workstation and flammable powders next to an area with explosion potential.
In addition to the fire and explosion dangers, other serious hazards included the use of unapproved electrical equipment; electrical equipment and wiring that were unsuitable for a hazardous location; failure to train employees on chemical hazards and safeguards; failure to supply employees with all necessary protective clothing, equipment and training; no written respiratory protection program; and failure to post danger tags in potentially explosive areas.
There are also multiple reported incidents of fire hazards or explosions in the news, including one that apparently resulted in death.
3. Elements of 3D Printing Safety
3D printing safety is an area of continuing research. The following sections offer more details on applicable guidelines and standards that have been provided by different standards bodies, manufacturers and institutions like universities. These guidelines, where relevant, need to be incorporated into your safety program.
3.1 OSHA Standards Compliance
OSHA laws and standards would form the baseline for your safety program. These would include at least the following:
- Respiratory protection (29 CFR 1910.134)
- Eye and Face Protection (29 CFR 1926.102)
- Electrical Protection (29 CFR 1910.137)
- Machinery and Machine Guarding (29 CFR 1910.212)
- Fall Protection – Training Requirements (29 CFR 1926.503)
- Ventilation (29 CFR 1910.94)
- Hazard communication standard (29 CFR 1910.1200)
- Medical and First-Aid (29 CFR 1910.151)
- Fire Protection (29 CFR 1910 Subpart L)
- Materials Handling and Storage (29 CFR 1910.176)
- Toxic and Hazardous Substances (29 CFR 1910 Subpart Z) <==Standards missing for 3D Printing PA 11/12, metal powders, and such.
- Hazardous Locations (29 CFR 1910.307)
- Occupational exposure to hazardous chemicals in laboratories (29 CFR 1910.1450)
- Recording and Reporting occupational Injuries and Illness (29 CFR part 1904)
- OSHA Safety Signs Guide
3.2 Manufacturers’ Materials and Operational Safety Guidelines
It is important to understand, train employees, and follow the safety guidelines provided by the manufacturer with each equipment and the materials being used in the lab. These include Safety Data Sheets (SDS) for 3D printers, sintering machines, bead blasting machines, for materials like polyamide and metal powders etc.
Your safety program will include these under the umbrella of OSHA standards.
3.3 UL Chemical Safety (UL 2904) Standards for 3D Printing
UL Chemical Safety group in coordination with Georgia Institute of Technology conducted an initial study on 3D printing in the context of emissions and air pollution, chemical exposure, flammability and human health.
Another study done by UL in collaboration with University of Texas discusses hazards in 3D metal printing, in relation to ultrafine particles (UFPs), volatile organic compounds (VOCs) and toxicity of fumes.
The current standard released by UL is named ANSI/CAN/UL2904. While this is mainly targeted at 3D printing manufacturers, these have impact on operators and lab environments as well, and will be of special concern in a R&D setting where experimental machines could be in use.
3.4 NFPA & OSHA Combustible Dust Hazards Guidelines
Powder processes used in 3D printing may result in “combustible dust”. Both metal and polyamide powders are used in additive manufacturing. Metal powders are especially known to be combustible. It is expected that powder vendors provide sufficient safety precaution guidelines on handling of these materials. For example, in the case of 3D printers manufactured by HP, vendors of these powders include GKN Powder Metallurgy for metal powders, and BASF, Arkema, Evonik, Henkel, Dressler Group etc. for PA 11/12 polyamide powders.
OSHA also defines hazard communication guidelines that need to be followed. This is covered in the publication 3371-08: “Hazard Communication Guidance for Combustible Dusts”. This does not cover 3D printing materials per se, but the guidance still applies.
The dust explosion pentagon chart is of relevance in this context. The NFPA (National Fire Protection Association) combustive dust standards outline the best methods for managing and cleaning up combustible dusts. These are covered in NFPA 499, NFPA 652 & NFPA 654 standards. NFPA 72, the National Fire Alarm Signaling Code standard also applies in this case.
3.5 NIOSH/NTRC Study and Recommendations for 3D Printing
National Institute for Occupations Safety and Health (NIOSH under CDC) conducted an initial study under their Nanotechnology research center (NTRC) in collaboration with an industry vendor to study the effects of 3D printing on health and safety.
The average size of polyamide (thermoplastic) powders range from 10 microns to 50 microns. These micro particles can be a health hazard as they possibly might penetrate into lungs, skin and the blood stream. Majority of printer emissions are nanoparticles, and these too can have an impact in health. NIOSH states that emissions in certain cases have been linked to asthma.
Recommendations from NIOSH are primarily in the area of ventilation, filtration, and managing fumes.
3.6 FDA Technical Considerations for Additive Manufacturing
The Food & Drug Administration (FDA) regulates biomedical devices and equipment (among others), including those that are created by 3D printing. There is ongoing research on the accuracy, reproducibility, stability, and suitability of 3D printed biomedical implements and parts. The National Center for Biotechnology Information (NCBI) under the National Institute of Health (NIH) recently conducted a study and concluded that unsatisfactory accuracy was a major concern for such parts. If a medical device, surgical guide, or implant is directly printed in a medical setting, then the entire process, including how the 3D printed model is produced, must be reviewed and approved by the FDA.
The FDA has released a draft “Technical Considerations for Additive Manufacturing Devices”, with safety as one of the key concerns.
3.7 Universities 3D Printing Safety Guidelines
Yale University, Purdue University, University of California at San Diego, Penn State, University of Vermont, University of Florida, and many others have publicly released their safety guidelines for the use of 3D printers.
These relate to training, engineering controls, work practices and personal protection equipment (PPE).
4. Creating a Safety Program
The following sections discuss how a safety program may be created for 3D printing labs. These primarily involve applying principles of hazard control, behavior based safety, and 3D printing safety concerns listed earlier, into the safety & health program guidelines provided by OSHA. These are briefly covered below.
4.1 Hierarchy of Hazard Control
This is a widely accepted system used in the industry to minimize and eliminate exposure to hazards. It consists of the following as shown in the diagram:
Elimination removes the hazard. Substitution replaces a hazard with something or a method that is not hazardous. Engineering Controls are meant to isolate people from hazards. Administrative Controls change the way people work, such as process changes and training, hazard. PPE (Personal Protective Equipment) protects the workers using equipment such as gloves, respirators, safety goggles, flame resistant lab coats etc.
A suitable hierarchy of controls need to be devised for 3D labs operations.
4.2 Behavior-Based Safety (BBS)
Behavior-Based Safety (BBS) creates a safety partnership between management and employees. It is based on continuous observation. BBS focuses on what employees do, analyzes why they do it, and applies intervention strategies where required.
When implementing a BBS program, observers conduct review of employees by focusing on their behavior (as far as work processes go). They record safe and unsafe behaviors, as well as safe and unsafe working conditions. The observer discusses findings with the employees and management, targeting positive feedback. Safety professionals use the collected data to continuously improve the BBS program.
To enable the BBS program, a list of behaviors that need to be monitored needs to be created, based on the behaviors and risks at the workplace.
OSHA does not mandate a BBS program, but the latter falls into OSHA recommendations that cover the involvement of manager and employees in safety and hazard identification and assessment.
4.3 OSHA Recommended Safety & Health Practices (SHP)
OSHA provides a set of recommended practices for setting up safety & health programs. These cover the following areas:
- Management Leadership
- Worker Participation
- Hazard Identification & Assessment
- Hazard Prevention & Control
- Education & Training
- Program Evaluation and Improvement
- Communication and coordination for host employers, contractors and staffing agencies
To get the program started, OSHA recommends ten steps to be completed that will help create a solid base. These are:
1. Set Safety and Health as a top priority
2. Lead by example
3. Implement a reporting system
4. Provide Training
5. Conduct Inspections
6. Collect hazard control ideas
7. Implement hazard controls
8. Address Emergencies
9. Seek input on workplace changes
10. Make Improvements
4.4 OSHA Metrics
What cannot be measured cannot be managed. OSHA standards also provide guidelines on metrics that are applicable to Process Safety Management. OSHA publication 3896 lists out various metrics that are applicable for process safety.
These are categorized as lagging metrics and leading metrics. The former is post-facto incidents and the latter is meant for preventive intervention. The associated metrics package is covered separately in another document.
4.5 Crafting a Safety Program
All the above inputs discussed in this document may be considered in creating a safety program. A schematic view of this is presented below.
5. Conclusions
A Safety Program for 3D printing environments can be created based on OSHA recommendations and guidelines. In such a program, safety elements related to 3D printing as available today, and behavior based safety (BBS) practices can be incorporated. These elements have been covered succinctly in the above sections.
As 3D printing is still a maturing technology, it is also important to keep an eye out for the latest research and publications in relation to its materials and operational safety, and incorporate them into the safety program where applicable. Please see the References section below for more details.
6. References
1. OSHA standards
2. OSHA cites 3D printing firm for metal powder explosion
https://www.osha.gov/news/newsreleases/region1/05202014
3. NIOSH – Characterizing 3D printing emissions and controls
https://blogs.cdc.gov/niosh-science-blog/2018/08/16/3d-printing/
4. UL Chemical Safety 3D printing findings
https://ohsonline.com/articles/2018/11/19/warning-signs-in-new-3d-printing-findings.aspx
5. ANSI/CAN/UL 2904 Technical Brief – Standard Method for Testing and Assessing Particle and Chemical Emissions from 3D printers
https://ulchemicalsafety.org//wp-content/uploads/2019/05/3DPrint_Standard_Brief_Version-2.pdf
6. Chemical composition and toxicity of particles emitted from a 3D printer
https://ulchemicalsafety.org//wp-content/uploads/2019/09/acs.est_.9b04168.pdf
7. NIOSH – Control Measures Critical for 3D Printers
https://www.cdc.gov/niosh/research-rounds/resroundsv1n12.html
8. NTRC – Nanotechnology Research Center – Additive Manufacturing reports
https://www.cdc.gov/niosh/programs/nano/default.html
9. A Study on Recycling of Waste Polyamide 12 Powder (2019)
10. OSHA HAZCOM for Combustible Dusts
https://www.osha.gov/Publications/3371combustible-dust.html
11. NFPA Standards on Combustible Dust
https://www.nfpa.org/Codes-and-Standards/All-Codes-and-Standards/List-of-Codes-and-Standards
12. FDA’s Role in 3D Printing
https://www.fda.gov/medical-devices/3d-printing-medical-devices/fdas-role-3d-printing
13. FDA Technical Considerations for Additive Manufactured Medical Devices
https://www.fda.gov/media/97633/download
14. Yale University – 3D Printer Safety Guidelines
https://ehs.yale.edu/sites/default/files/files/3D-printer.pdf
15. University of Vermont – 3D Printer Safety Guidelines
https://www.uvm.edu/riskmanagement/3d-printer-safety
16. University of Florida – 3D Printer Policy (Environmental Health & Safety)
https://www.ehs.ufl.edu/programs/os/3d-printer-policy/
17. Purdue University – Health & Safety guidelines for 3D printers
https://www.purdue.edu/ehps/rem/documents/sops/sop3Dprinters.docx
18. UC San Diego – Additive Manufacturing – 3D Printer Safety
https://blink.ucsd.edu/safety/occupational/hazard-control/3d-printing.html
19. OSHA Safety & Health Programs - Recommended Practices
https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf
20. Center for Behavioral Safety – Case Studies
https://cbsafety.com/client-results/case-study-one/
Appendix - Sample Safety Manual TOC
The following is a sample table of contents (TOC) for creating a Safety Manual, adapted from open source (weeklysafety.com).
Section 1 CORPORATE SAFETY POLICY
Section 2 COMPANY POLICIES AND PROCEDURES
Program Requirements........................
Written Individual Programs................
Health and Safety Program Responsibility
Job Safety Planning and Analysis.........
Routine Safety and Health Inspections
Safety Meetings...................................
Hazard Reporting.................................
First Aid Procedures.............................
Accident Investigation.........................
General Safety Rules for all Employees
Fire Prevention and Protection............
Evacuation Procedures........................
Recordkeeping Requirements.............
Disciplinary Actions for Willful Unsafe Acts
Section 3 HAZARD COMMUNICATION PROGRAM
Program Requirements........................
Responsibility.......................................
Training Requirements.........................
Labeling Requirements........................
Safety Data Sheets and Hazardous Materials Inventory List......
Non-Company Employees Program....
Trade Secrets.......................................
Non-Routine Tasks...............................
Chemical Storage.................................
Lead industrial / mechanical designer, ALOGIC, Monitor category
9 个月Well done, great to see this very comprehensive post on safety for 3D printing. Thank you.