Punch Press Injury — When the Guard Is Missing, the Injury Is Foreseeable

Punch Press Injury — A Guard Was All That Was Missing

Let's talk about what happened at Larkin Storage and Retail Equipment Inc.'s manufacturing facility in Alexandria, Ontario on September 16, 2020. The company manufactures warehouse racking and retail fixtures — work that involves forming and punching sheet metal. One of the production machines was a punch press. A worker was manually guiding a piece of material through the punch press when the punch descended and struck the worker's hand. The injury happened because the machine was not equipped with a guard that prevented access to the exposed moving punch — the part of the machine that is specifically designed to come down with force. In its incident report to the Ministry of Labour, the company identified two contributing factors: a lack of training and inadequate guarding. That self-assessment is accurate and complete. And it describes a violation of Ontario Regulation 851 that had existed in the facility before the incident. The company pleaded guilty in the Ontario Provincial Offences Court in Cornwall and was fined $65,000 plus a 25% victim fine surcharge.

What the Law Requires

Section 24 of Ontario Regulation 851 is direct: 'A guard or other device shall be provided for a part of a machine, other than a part that is designed so that it cannot endanger any person, that is or may be a source of danger to a worker.' Basically, what this means is simple: any part of a machine that can hurt a worker must be guarded. The punch of a punch press is the defining example of a machine part that is a source of danger. The punch descends with enough force to form or cut metal. The regulation requires a guard that prevents access to that punch while the machine is operating. A machine without that guard is a non-compliant machine. A worker operating a non-compliant machine without proper training is doubly exposed. The company's own incident report acknowledged both failures. Section 25(1)(c) of the OHSA requires employers to ensure that prescribed measures are carried out — including the guarding requirements of Ontario Regulation 851. In the court's view, this was not a complex or ambiguous situation — it was a machine that lacked the guard it was legally required to have, operated by a worker who had not been trained on the correct method for using it safely. The $65,000 fine reflects the directness of the regulatory breach and the preventability of the injury.

What Supervisors Must Do

• Conduct a walkthrough of all production machines under your supervision and confirm that every machine with exposed moving parts has the appropriate guard installed and functioning
• Before assigning any worker to operate a punch press or similar machine, confirm they have been trained on the correct operating method, including how to position material without reaching into the point of operation
• If a guard is missing, damaged, or has been removed, tag the machine out of service immediately — do not allow production to resume until the guard is replaced and confirmed functional
• Include machine guarding in your monthly equipment inspection checklist; guards that were present last month may be absent this month — verify them each cycle
• Keep asking: 'If that worker's hands slipped right now during this operation, what prevents them from reaching the point of operation — and is that protection in place?'

What Employers Must Do

• Conduct a machine inventory and guarding audit for every production machine in your facility against the requirements of Ontario Regulation 851; document the results and act on every gap
• Develop machine-specific safe operating procedures for every punch press, power press, and similar machine; procedures must specify exactly how to position material, where hands must be, and what the guard must cover
• Implement a pre-shift machine inspection for all punch presses and power presses; the operator must confirm that the guard is in place and functioning before starting production
• Train every worker who operates a punch press on the specific guarding requirements and on the safe operating procedure for that machine before they use it for the first time
• Review your incident reporting process to ensure that when your own reports identify guarding deficiencies, those deficiencies are tracked and corrected before the next shift — not just noted
• Include machine guarding compliance in your annual OHSA self-audit; if any machine lacks a required guard, it must be corrected before that machine is returned to production

How to Use This Case in Your Workplace

This case is a valuable safety conversation starter. Use it during monthly safety meetings for all production workers, machine-specific training for operators of punch presses and power presses, and annual guarding audits in manufacturing facilities. Walk your team through the production floor and ask: 'Does every machine with a moving punch, die, or blade have a functioning guard that prevents access to the point of operation during the work cycle?' 'When was the last time we confirmed that all guards on all machines are still installed — not just that we once installed them?' 'If a new worker were assigned to this machine today, what would they be trained on before their first shift?' This case reinforces a simple message: a machine guard is not just a compliance item — it is the physical barrier between a worker's hands and a part that is designed to cut, form, or punch with enough force to cause serious injury. When the guard is gone, the injury is waiting.