Lock-out/Tag-out Update

The American Forest & Paper Association appreciates the opportunity to submit the following comments in response to OSHAs Request for Information (RIF) regarding potential revisions to the agencys Control of Hazardous Energy (Lockout/Tagout) standard. The American Forest & Paper Association (AF&PA) serves to advance a sustainable U.S. pulp, paper, packaging, tissue and wood products manufacturing industry through fact-based public policy and marketplace advocacy. The premise of this OSHA initiative is to modernize the OSHA Lockout/Tagout (LOTO) Standard in a way that better promotes worker safety without placing additional burdens on employers. This would be accomplished by formally recognizing the use of control circuit devices in lieu of lockout where they provide effective protection from exposure to hazardous energy sources within the scope of the OSHA LOTO Standard. Based on that premise, we strongly support this initiative. The RFI also notes that OSHA may consider changes to the Lockout/Tagout standard that address hazardous energy control for new robotics technologies. Before responding to the specific questions included in the OSHA RFI, AF&PA would like to offer the following overarching comments: The objective of the OSHA LOTO Standard should be to protect employees from injury resulting from unexpected (accidental or inadvertent) exposure to hazardous energy sources when machine safeguarding measures do not provide adequate protection to employees performing maintenance and servicing activities on machines and equipment. The OSHA LOTO Standard is thirty years old and is based on technology and knowledge from the 1970s and 1980s. The primary OSHA Machine Guarding Standards are 45 years old. Their approaches to the control of hazardous energy do not fit the technology and methods available in industry and cannot keep up with advances in technology. Hence, modernization of 29 CFR 1910.147 is clearly needed. Control Circuit Devices In the Safety Hierarchy of Controls, effective Engineering Controls, such as safety-related control systems, are greatly preferred over Administrative Controls, such as lockout, because they are far more reliable and, therefore, have a much greater probability of avoiding harmful exposures. Lockout/Tagout is an Administrative Control that is susceptible to human error, whereas safety control circuit device failure rates are significantly lower than human error rates. If OSHA would formally recognize the longstanding use of control circuit devices in lieu of lockout where an appropriate risk assessment method has been conducted, particularly for routine tasks such as, but not limited to, set-up, cleaning, and jam clearing, it would result in: Enhanced safety and injury prevention A reduction in complicated and unnecessary lockouts Increased employee compliance Reduced potential for human error Simplified employee training for those tasks Increased credibility for the OSHA LOTO regulatory scheme. Particular examples of tasks where control circuit type devices and other alternative methods could be and may already be used to achieve a level of safety performance at least equivalent to lockout in the paper industry include: Paper Machine Winder oThreading (still requires some power but could remove energy from all other hazardous energy sources to which the employee would otherwise be exposed) oAdjusting slitter blades oSetting cores oTaking samples and measurements Corrugated Box Plant Flexo Folder Gluer oChanging print plates between print runs oCleaning anilox rolls between print runs oClearing minor jams oPulling product samples or opening interlocked guards to remove product samples (after machine stop) oMinor adjustments (folding arms) This is a limited list and there is potential for many additional applications of safety control circuit devices for lockout. Robotics Robot systems employed by the paper industry are generally built by the Original Equipment Manufacturers (…