Lockout/tag

Oct 16, 2023

Industry trade groups have weighed in — both pro and con — on whether the Occupational Safety and Health Administration should update its 30-year-old lockout/tag-out rules.

The proposed change reflects improvements in circuit control-type devices, such as push buttons, selector switches, e-stops and secure shutoff keys.

It's a huge debate that could impact all U.S. industrial manufacturing — including plastics. Arguments by companies and trade groups favoring a change to circuit control-type devices include that they increase manufacturing efficiency and flexibility, are cost-effective and are as safe or safer than the traditional LOTO method, while taking much less production downtime to implement.

OSHA's proposal is in the very early stage. The agency is asking for comments, but OSHA has not actually proposed a draft rule.

"While the traditional control of hazardous energy has relied on locking out an energy-isolating device, advances in control systems now allow for alternative methods to control hazardous energy," the American National Standards Institute's B11 standards development committee wrote in its comment to OSHA.

OSHA uses both the terms lockout/tag-out and "the control of hazardous energy" to describe this fundamental safety measure that, along with proper machine guarding, is designed to protect factory workers from amputations and even death.

Comments from people opposed to changing LOTO cited safety issues, cybersecurity threats and problems with the circuit control devices themselves because of improper installation.

The Plastics Industry Association said the "significant efficiencies" provided by the alternative control method "are critical to the ability of U.S. industries to compete in a global economy."

The plastics group is asking OSHA to to explicitly recognize the use of reliable control circuits rather than LOTO to protect workers from exposure to hazardous energy sources.

Industrial machinery can be dangerous. For example, injection molding presses have pinch points and dangers of crushing, especially in the mold clamping area.

Serious accidents can bring big OSHA fines, worker lawsuits and public humiliation. In a worst-case scenario, Michigan OSHA slapped files totaling $558,000 on Grand Rapids Plastics Inc. in Wyoming, Mich., after worker Russell Scharenbroch was fatally crushed in mid-2014 inside an injection molding machine he was cleaning and another worker accidentally cycled the machine. The company did not enforce lockout/tag-out safety procedures, and the press did not have a safety gate to prevent a worker from entering the area, MIOSHA said.

MIOSHA found a pattern of employees entering the machines while the presses were still energized and other safety violations. The molder also did not adequately train employees in LOTO. His widow filed a wrongful death lawsuit. Fiat Chrysler Automobiles pulled business from the company, and Grand Rapids Plastics closed in 2016.

OSHA is especially focusing on amputations from LOTO, which could include even a fingertip injury, two lawyers who specialize in workplace safety said at the Environmental Health and Safety Summit in June, organized by the Manufacturers Association for Plastics Processors.

Current LOTO rules require all energy be disconnected before serving and maintaining industrial machinery.

OSHA sought comments on its existing standard that dates to 1989, calling for controlling sources of energy by energy isolating devices (EID) and changing that to circuit control-type devices. OSHA received more than 85 comments by the agency's deadline of Aug. 19.

An EID is a mechanical device that physically prevents the transmission or release of energy — for example, a manually operated circuit breaker or a disconnect switch — deenergizing the machine and physically locking it out.

Circuit control-type methods use electronic control and switches to protect employees from potentially hazardous released energy.

The original OSHA regulations specifically excluded circuit control-type devices from lockout/tag-out, including push buttons, selector switches and other similar devices.

But advocates of changing OSHA regulations to circuit control devices — including the Plastics Industry Association — say the technology has dramatically improved since 1989, making the sensing devices a reliable source to prevent employees from injury from unexpected hazardous energy. The standard should be modernized to reflect the new technology, they argue.

ANSI's B11 standards committee has 32 members from companies and industry organizations, including the Plastics Industry Association, the Robotic Industry Association and the Association for Packaging and Processing Technology (PMMI).

The Plastics Industry Association and PMMI also made separate comments supporting the change.

Cost reductions would come from shorter times for maintenance and servicing activities, the Plastics Industry Association said. The trade group asked its members to give examples in which safety control circuits, rather than lockout/tag-out, improve productivity.

The plastics association gave mold changes as one example to show the difference. Applying lockout/tag-out to mold changes — instead of the industry's current method of using circuit controls — would remove one hour of production each day for one press if LOTO rules called for shutting down the heaters that keep the plastic in a molten state, or 30 minutes if the heaters did not have to shut down.

The Plastics Industry Association estimated there are about 450 factories in Michigan that operate an average of 30 injection molding machines. Based on two mold changes per week on 30 presses and a cost of $60 per machine per hour, the downtime could add up to about $187,000 when shutting down the heaters or $93,000 if the heaters can stay on.

Using traditional LOTO vs. control circuit systems would increase the time to complete setup tasks by about 50 percent, the association said.

The plastics trade group also gave comparison data for other processes, such as work changes on flexographic presses, blown film extrusion, pallet wrapping equipment and programing a robot at a packing station.

PMMI, the packaging trade association, said the current LOTO regulation "has created significant compliance defense costs, impeded the use of advanced technologies and best practices and inadvertently affected industry competitiveness in a negative manner." PMMI also gives time and cost numbers showing the circuit control-type methods are improvements over LOTO. Examples include cleaning and clearing jams in a can filling line and a bottling line.

PMMI's filing shows examples of alternatives that are already being used in high-output packaging operations, including slide locks to prevent an unexpected restart, "trapped keys" that only can be accessed by qualified people and a system that uses two independent safety circuits for each variable frequency drive on an automated robotic case packer.

The Council of Manufacturing Associations also supports OSHA considering the control circuit type devices as an alternative to LOTO. Members, including the National Association of Manufacturers, surveyed their membership and got 70 responses.

"There were virtually no reported instances of control circuit device failure," the council said. However, in "more process-focused industries, the preference is the control circuit needs to be physical and the worker must be knowledgeable of the system," the manufacturing group wrote. "There must be a certainty that disabling the control circuit would prevent the associated piece of equipment from moving or becoming energized in some way."

OSHA did hear from dissenters, including a union, the National Federation of Independent Businesses (NFIB) and the National Waste & Recycling Association (NWRA).

NFIB said that if OSHA decides to move ahead on rulemaking, the agency should "carefully consider cyber vulnerabilities" and not mandate circuit control-type devices or robotics to replace LOTO.

The trade group said OSHA's circa-1989 exclusion of circuit devices from the approved energy isolating devices meant a thumb pushing a button or a hand twisting a switch. But today that is likely to be someone using a keyboard on a computer — opening the system to hacking (or as NFIB wrote, "nefarious cyber-manipulation").

If OSHA ends up making the change, it should make it clear that the new systems are an alternative to, and not mandated replacement of, current lockout/tag-out using EIDs, said the trade group, which represents small and independent businesses.

NWRA said its members in the solid waste and recycling business opposed changing from LOTO. "As an organization, we [do] not believe that modernizing the control of hazardous energy regulations would increase the safety of our workforce," but rather "add confusion and unnecessary administrative controls when serving and operating machines in waste and recycling facilities," the trade group wrote.

NWRA's comments include photographs and descriptions detailing how a lack of a training protocol for electricians and maintenance technicians could lead to a control circuit system where safety circuits are bypassed.

The International Brotherhood of Electrical Workers union "strongly opposes" expanding LOTO to include the use of circuit control devices alone.

"Control circuit-type devices can and should be used as a redundant indicator that mechanical devices are properly positioned to protect workers" but they should not be the only provider of protection from hazardous energy sources, IBEW wrote.

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