Special Report: Lockout/tagout changes spur debate for manufacturers
New and proposed safety rule changes are sparking heated debate for some manufacturers. At the national level, the proposed elimination of a single word from OSHA's Control of Hazardous Energy Lockout/Tagout standard carries significant ramifications. Meanwhile, Michigan injection molders are adapting to new lockout/tagout procedures for mold changes on horizontal injection molding machines.
One of the industry's greatest concerns is that the changes will increase costs and make U.S. manufacturers less competitive globally — without actually improving worker safety. Industry leaders are weighing in on the national standard, telling OSHA that the proposed change would put the U.S. out of sync with global standards.
What is the OSHA standard?
OSHA's current standard on the Control of Hazardous Energy (29 CFR 1910.147) states that "Lockout/tagout refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities."
The agency's October Standards Improvement Project (SIP) IV proposed removing the word "unexpected." SIPs are used to remove or revise duplicative, unnecessary and inconsistent safety and health standards, OSHA said. The agency believes that the change would eliminate confusion regarding how the standard is applied.
Therein lies the issue. How will removal of "unexpected" be interpreted and what are the implications for the plastics industry? This is the wording of the current standard: "Employees can be seriously or fatally injured if machinery they service or maintain unexpectedly energizes, starts up or releases stored energy."
Machines that could release such energy must be shut down according to the OSHA standard, using energy-isolating devices, such as manual circuit breakers or switches. Depending on the situation, the energy-isolating devices must either be protected by locking mechanisms or prominently identified with warning devices, so workers do not start up a machine in a way that would release dangerous energy. The standard applies to all sources of energy, including mechanical, electrical, hydraulic, pneumatic, chemical and thermal sources. Therefore, the removal of the term "unexpected" would have significant impact across numerous industries.
It's a substantive change to the standard and should not be allowed without OSHA following the rulemaking process as required under the Occupational Safety and Health (OSH) Act of 1970, said Bruce Main, who is president of Design Safety Engineering Inc., Ann Arbor, Mich. He is also chairman of the committee that drafted a voluntary consensus standard for American National Standards Institute (ANSI), known as ANSI B11.0 Safety of Machinery. He said OSHA is trying to make small adjustments to the wording of a standard that is over 25 years old and out of date.
"Single-word changes or new interpretations will not improve this situation," Main said.
OSHA, for its part, said that SIP IV is undertaking a rulemaking process and follows the notice and comment procedures required by the OSH Act, which established the agency.
"OSHA will review all comments submitted regarding the proposed rule," said Kimberly Darby with OSHA's Office of Communications. "The final rule may differ from the proposed rule. The next step will involve reviewing all the comments received. We do not have an estimate as to how long the review process will take."
Industry group says: Keep the word
The Plastics Industry Association, Washington, D.C., believes the proposal should be withdrawn. Officials have submitted comments to OSHA, which planned to accept stakeholder comments through Jan. 4.
The association said the word "unexpected" is important and was used pervasively in the original lockout/tagout standard. In addition, it argues that it is inappropriate for OSHA to propose such a material change in a SIP, said Marie Gargas, the association's senior technical director, environment, health and safety.
"Removing the word is not just a clarification or reduction of regulatory burden, which is the purpose of a SIP; it can add burden, and it is a more substantial change than should be added through SIP," Gargas said. This proposal would instead impose potentially substantial new requirements.
The association "believes OSHA should withdraw the proposed amendment and pursue a separate rulemaking to update 29 CFR 1910.147 to reflect current technological advances," Gargas said. "OSHA already has a lockout/tagout update planned."
OSHA's spring and fall 2016 regulatory agendas both included line items to discuss updating the standard for logout/tagout, sometimes referred to as LOTO.
"We agree that that is the proper way to address it, so OSHA should go forward with the LOTO update and enable broader discussion," Gargas said. The association has worked with OSHA on lockout/tagout and machine guarding in the past. Following this process would allow stakeholders to more fully review the potential benefits and drawbacks of various options, advances in computer-based technology and various industry consensus standards.
The Michigan Rule
In Michigan, companies that use horizontal injection molding machines are dealing with the ramifications of having to comply with full lockout/tagout during mold changes — a requirement that went into effect Jan. 1. Unlike OSHA, Michigan OSHA (MIOSHA) has had injection molding-specific regulations, and since 1992, these regulations have offered an alternate lockout/tagout procedure for mold changes, Main said.
SIDEBAR: Why is Michigan different?
OSHA's efforts to harmonize the rules come at a price, he said. "Every time you change a mold, you have to do lockout, and the cost can be quite significant." Main explained that MIOSHA previously required only a lock on the access gate of the machine, so the clamping system would not restart.
Under the new rules, molders will need to add energy-isolating devices and panels, requiring new wiring. In addition, with a full machine shutdown, mold changes and machine restarts will take significantly longer, said Main, who quoted one estimate of an average of 1 hour of additional downtime a day per machine.
Main said the rule change goes into effect, even though no incidents had occurred under the processes formerly approved by MIOSHA.
"For 24 years, this method has been used, and MIOSHA knows of no reported injuries or incidents," he said. "Yet, a properly designed and implemented, control-reliable safety system can be used for mold changes and keep workers safe from harm. Prohibiting the use of technological solutions where they can be effectively and safely used doesn't make very much sense. Workers deserve better. So do employers. MIOSHA is changing the rule because federal OSHA is pushing them to do so."
Further complicating the situation for Michigan molders is a pending change to the ANSI/PIA B151.1 standard for injection molding machines. The revised industry standard will eliminate the requirement for jam bars for horizontal injection molding machines. To both Main and David Palmer, director of the Equipment Council for the Plastics Industry Association, the bars represent "redundant redundancies"; unlike in other states, though, they'll still be required in Michigan under MIOSHA's Part 62 requirements.
"There's no mandate for federal and state governments to change their own standards based on the publication of these ANSI standards," Palmer explained. The situation subjects Michigan molders to standards that exceed OSHA's own.
Machines without the jam bars cost less, Main said, but whether Michigan molders will opt for them remains to be seen. Meanwhile, they will surely feel the burden of the new lockout/tagout requirements. "I just don't think that OSHA understands the true cost of this," he said. Citing the Plastics Industry Association, he said every Michigan molder is expected to lose $187,000 to $2 million per year because of the change, a statewide loss of about $84 million annually.
Some exceptions apply to MIOSHA's full lockout/tagout procedures:
• Minor servicing during normal production operations. This includes some lubricating, cleaning and unjamming activities, with employers responsible for making decisions on a case-by-case basis.
• The use of machine guarding. It can be considered an effective alternative to lockout/tagout procedures if it eliminates employee exposure to the hazardous energy source.
• The use of a separate energy-isolating device, in some situations. It is allowed if it can be locked out during mold changes for motors, pumps or other equipment that exposes workers to a potential hazard, while leaving power on to heating elements and computer controls.
Increased Safety?
Will these changes increase worker safety? What do they mean for the competitiveness of U.S. molders?
David Preusse, president of Wittmann Battenfeld Inc., Torrington, Conn., said while his company's machines are in full compliance of all regulations — "old, new, even proposed," the new standards could create unforeseen consequences for processors. "Many Michigan molders are only now engaging in the new standard and considering how to react and adopt the new rules," he said. "I am concerned if the literal meanings of standards changes stick and are enforced, that U.S. molders will continue to be less efficient [than] the global plastics markets in which they must compete," Preusse said. "Worst of all is if the changes don't make the users more safe, but just cost more."
Lisa Jo Lupo, correspondent
Contact:
OSHA's current Control of Hazardous Energy Lockout/Tagout rule can be found at www.osha.gov/Publications/3120.html
