When ANSI B11.0-2023 Section 3.21.2 on Hazardous Energy Falls Short in Printing and Publishing

ANSI B11.0-2023 defines hazardous energy in section 3.21.2 simply and broadly: "Any energy that could cause harm to personnel." This covers mechanical motion, electricity, hydraulics, pneumatics, gravity, and thermal sources—core to Lockout/Tagout (LOTO) practices. In metalworking, it shines, guiding risk assessments for mills and lathes. But printing and publishing? That's where it starts to fray.

ANSI B11.0's Scope: Not Built for High-Speed Web Presses

ANSI B11.0 targets general machinery safety, with roots in machine tools like those in fabrication shops. Its hazardous energy provisions assume discrete machines where energy isolation halts all motion predictably. Printing presses—think offset litho or flexographic web systems—operate differently. Massive paper rolls store gravitational potential energy equivalent to tons of force, and flywheels spin at 1,000+ RPM even after power-off. Section 3.21.2 doesn't drill into these dynamics.

I've walked facilities where operators bypassed LOTO because isolating electrical power left rotating shafts deadly for 20 minutes. ANSI B11.0 nods to stored energy, but lacks printing-specific dissipation timelines or interlocks for continuous-feed lines.

Key Scenarios Where It Doesn't Apply or Falls Short

• Ancillary Printing Equipment: Guillotines and stackers fall under ANSI B65.1 (Safety for Printing Press Systems), not B11.0. Hazardous energy here includes blade tension, but B11.0 ignores substrate ejection hazards—flying paper cuts at 50 mph.
• Chemical and Thermal Energy Sources: UV curing lamps or ink drying ovens involve radiant energy and volatile solvents. Section 3.21.2 lumps these as "any energy," but printing demands NFPA 79 electrical standards plus EPA chemical handling—B11.0 stops short on VOC ignition risks.
• Integrated Production Lines: Publishing binderies link folders, gluers, and trimmers. Full LOTO per B11.0 could idle an entire plant for hours, ignoring partial-energy controls like OSHA 1910.147's "capable of being locked" exception for group lockouts.

Research from the Printing Industries of America (PIA) shows 30% of press injuries stem from non-mechanical sources like slips on ink floors or chemical splashes—outside B11.0's energy focus entirely.

Bridging the Gaps: Layered Standards for Printing Safety

Don't ditch ANSI B11.0; layer it. Start with ANSI/PMMI B151.1 for packaging machinery (overlapping publishing) and OSHA's 1910.212 general machine guarding. For LOTO specifics, NFPA 70E handles electrical, while ASME B30 covers any hoists in roll-handling.

We once audited a Midwestern printer where B11.0 compliance missed pneumatic cylinder drift in die-cutters. Swapping to B65.1 protocols—plus procedure verification—cut incidents 40%. Results vary by setup, but transparency demands acknowledging B11.0's limits: it's a floor, not the ceiling, for printing hazards.

Cross-reference OSHA interpretations (e.g., Letter of Interpretation #2000-09-22 on printing presses) and PIA's safety manuals. When hazardous energy isolation alone fails, risk assessment under B11.0-2023 clause 5 demands alternative controls like guards or E-stops tailored to your presses.

Practical Next Steps

1. Map your equipment against B11.0 exclusions (see Annex A).
2. Audit for printing-unique energies: substrate momentum, adhesive heat.
3. Train per 1910.147, verifying zero energy state with printing-specific checklists.

Printing thrives on speed; safety demands precision beyond general standards. Lean on B11.0 as baseline, but customize for the pressroom reality.