OSHA "talks the talk" when it comes to stored hydraulic energy, but continues to ignore the "elephant in the room."

Here is a report of yet another mechanic that suffered a debilitating oil injection injury but, as usual, the mechanic, not the hydraulic system designer, shoulders the blame:

https://www.timberlinemag.com/articledatabase/view.asp?articleID=4167

Here are the erroneous, and unrealistic, statements under sub-heading “Recommendations.”

“At the time of the repair, the mechanic had not consulted the specific manual for this machine to determine the proper procedure to dissipate oil pressure throughout the system.”

FACT: There were no procedures in the manual for dissipating oil pressure in the system.

“During the accident investigation, the manual still could not be located. As increased technology has complicated shut-down procedures (the addition of hydraulic accumulators for example), no assumptions can be made, and a generic shut-down procedure should not be trusted.”

FACT: There is no such a thing as a “generic shutdown procedure” for a hydraulic system. Every hydraulic system is unique.

“Machine-specific owners’ manuals should be readily available and consulted prior to undertaking repairs.”

FACT: Machine specific owners’ manuals DO NOT provide information about how to determine if, after shutdown, a hydraulic system contains stored energy. Moreover, even if a person could determine if a hydraulic system contains a lethal amount of stored energy, there is no safe way to remove it.

“When searching for hydraulic leaks and servicing charged systems, heavy gloves will provide additional protection for the hands.”

FACT: There are no gloves currently available that will protect a worker from an oil injection injury.

This accident epitomizes the disparity between OSHA's standard (Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147), and the reality of the situation.

Here are a few excerpts from OSHA’s Control of Hazardous Energy (Lockout/Tagout) 29 CFR 1910.147:

? This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy.

FACT: Less than 1% of the hydraulic systems operating in the USA meet the minimum performance requirements for the control of hydraulic energy.

? This standard applies to the control of energy during servicing and/or maintenance of machines and equipment.

FACT: The standard may apply to other forms of energy, but it in no way, shape, or form applies to hydraulic energy.

? Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

FACT: Not only do ALL employers fail to establish a program consisting of energy control procedures for hydraulic systems, but they couldn’t even if they wanted to, because hydraulic systems are not designed to facilitate the safe and controlled release of stored energy.

? How do I know if the OSHA standard applies to me?

If your employees service or maintain machines where the unexpected startup, energization, or the release of stored energy could cause injury, the standard likely applies to you.

FACT: The standard does apply to you if you work on hydraulic systems. As you can see from this accident, you and your colleagues are highly susceptible to this type of accident because both your employer, and OSHA, ignore the problem.

? The standard applies to all sources of energy, including, but not limited to: mechanical, electrical, hydraulic, pneumatic, chemical, and thermal energy.

FACT: While OSHA’s Control of Hazardous Energy (Lockout/Tagout) 29 CFR 1910.147 applies to all sources of energy, including hydraulic energy, both your employer, and OSHA, ignore the fact that less then 1% of the hydraulic systems operating in the USA, Canada, Australia, Europe, et al, can be de-energized after shut down.

My recommendation: NEVER loosen a hydraulic connector, or remove a hydraulic component, unless you can verify if the hydraulic system you are working on contains stored energy. In all likelihood it does, and there is frankly no safe way to remove it.

Since your employer and OSHA ignore the problem, the only thing left for you to do, is to refuse to work on a hydraulic system if you have any doubt that it contains stored energy.

Here is a video of an accident I filmed while conducting a hydraulic cylinder performance test:

https://www.youtube.com/watch?v=1VYqoTpv5EU

The accident is identical to subject accident in which the victim suffered an oil injection injury. The victim in this accident performed the identical procedure described in the subject accident. As you can see from the video, the victim was fortunate in that the explosion was deflected toward the machine’s cab.

Post accident I installed a Safe-T-Bleed connector in the line, and repeated the procedure. The lowest pressure I could achieve after following the manufacturers‘ (Doosan) recommendations, was 500-PSI: a pressure well into the territory that could cause an unsuspecting person to suffer a debilitating oil injection injury.

The information in this blog applies to ALL industrial and mobile hydraulic systems - no exceptions! Before you work on any hydraulic system, read the respective manufacturers’ warnings about the consequences of discharging high-pressure hydraulic oil to atmosphere. Then, ask the respective manufacturer’s engineering department to write your company a letter stating that post shut down the entire hydraulic system on machine model XXXX de-energizes, and is thus completely safe to work on. Until you receive the letter, keep your hands, eyes and body away from hydraulic systems!

Hydraulic safety doesn't just happen, it must be vigorously pursued."