Is a “baler” a PRCS?

PR 9 Baler

To be blunt on a serious matter, MOST balers I have come across are indeed a PRCS.  Some can easily be reconfigured in order to reclassify using some simple LOTO practices to eliminate the hazard AND to open them up (LOCKED OPEN) which would put the tasks as a “maintenance task” and not an “entry into a PRCS.”  This week OSHA posted a $337,903 citation involving the death of a 20-year-old worker who had been on the job for nine months.  The worker was feeding cardboard waste into the baler on Feb. 7, 2022.  Debris jammed the machine, and as the young worker tried to remove the stuck cardboard, they fell into the machine. The worker died the next day at a hospital.  Here is a picture of the type and model OSHA noted in their investigation:

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