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OSHA, PLASTICS hash out updates on lockout/tagout rules

Issue: March 2018

The Occupational Safety and Health Administration (OSHA) continues to work on its lockout/tagout (LOTO) standard on two separate fronts.

As part of OSHA’s Standards Improvement Project IV, the agency proposed removing the word “unexpected” from the phrase “unexpected energization” in its general industry standard for the control of hazardous energy (LOTO), 29 CFR 1910.147.

In its official comments submitted to OSHA, the Plastics Industry Association (PLASTICS) said it “opposes the removal of the word ‘unexpected’ from the phrase ‘unexpected energization or start up or release of stored energy.’ The importance of the word ‘unexpected’ is clear from its pervasive use in 29 CFR 1910.147, consistent with the industry-
consensus standard on which it was based, and the underlying principle of the decision in GMC Delco — that LOTO is not required where reliable control circuitry provides effective protection to employees from the potential for ‘unexpected energization or start-up or release of stored energy.’ Eliminating the word ‘unexpected’ would be a material change to 29 CFR 1910.147.”

At press time, OSHA was planning to issue a final rule in February.

At issue in the GMC Delco case, Secretary of Labor v. General Motors Corp. (GMC), Delco Chassis Division, was whether the company was liable when its employees failed to de-energize and lock out machines. Because power to such machines could be considered “expected,” GMC was successful in showing it had committed no violations, despite several appeals by OSHA.

In addition to participating in the debate over whether to include the word “unexpected,” the association is preparing for other proposals to update 29 CFR 1910.147.
OSHA plans to issue a request for information (RFI) in May to potentially update the standards. This is to address technological advancements, conflicts with OSHA’s standard, international harmonization and other issues that arise through the RFI. The industry association intends to respond to the RFI.

Elsewhere, there has been no change in the status of the rule that went into effect Jan. 1, 2017, requiring companies in Michigan that use horizontal injection molding machines (HIMMs) to comply with full LOTO during mold changes — a rule put forth by Michigan OSHA (MIOSHA). The rules had allowed for an alternate LOTO procedure previously.

“PLASTICS’ advocacy has been ongoing,” said Marie Gargas, senior technical director, regulatory affairs for PLASTICS. “We requested an amendment process in July 2017 to remove the requirement for a mechanical device (jam bar/drop bar) on HIMMs built on or after Jan. 7, 2017, that comply with ANSI/PLASTICS B151.1-2017. MIOSHA responded favorably in that they will consider our request. We have worked with members and consultants and are close to finalizing and submitting draft language for MIOSHA’s review and consideration.”

Phillip Britt, correspondent



Plastics Industry Association
Washington, 202-974-5200, www.plasticsindustry.org