New Injection Machine Safety Standards in Michigan Could Have National Consequences

New rules from MIOSHA could require complete machine shutdown--even of barrel heaters--during mold changes.

In a bid to have the state’s safety guidelines better reflect the national standard, the Michigan Occupational Safety and Health Administration (MIOSHA) will start enforcing new machine safety guidelines that have sparked more questions than answers for molders and machinery suppliers. What’s more, there is concern that a rule change by the influential Michigan state safety agency could be adopted by other states.

Effective Jan. 1, 2017 operators of horizontal injection molding machines in Michigan will be required to comply with full lockout/tagout (LO/TO) requirements if there is the potential for harmful exposure to hazardous energy sources during maintenance and servicing activities. Previously, mold changes through either the front or rear gate of a horizontal injection press were allowed as long as the machine had a functional mechanical safety plus two independent interlocks on the operator’s gate, as well as an emergency or other stop that would shut off the motors that actuate the clamp.

MIOSHA has now changed the rule—Part 62 Plastic Molding Safety Standard R408.16234—so that it meets U.S. OSHA’s General Industry Safety Standard Part 85 “The Control of Hazardous Energy Sources.” By Dec. 31, molders are instructed to phase out procedures that allow for either the front or rear gates of a horizontal press to be locked in the open position during mold changes. MIOSHA recognizes that complying with the Part 85 Lockout standard might not be possible on some machines without shutting down the press’s heating system.

MIOSHA has stated that there are exceptions to the LO/TO requirements. These include maintaining or servicing presses if there is machine guarding that’s deemed capable of eliminating exposure to “hazardous energy.” David Palmer, SPI’s director of industry affairs—Equipment Council, noted that MIOSHA deems routine mold or die changes to be maintenance and servicing activity. According to OSHA CPL 02-00-147, setting up is “any work performed to prepare a machine or equipment to perform its normal production operation.” Setting up is not considered utilization of a machine or equipment and is classified as servicing and/or maintenance, rather than normal production operations.

Machinery suppliers have pointed out to MIOSHA that during a tool change molders want to maintain heat and have access to a powered-up control, and the agency has recognized that, noting that “it would be allowable to use a separate energy-isolating device that can be locked out during the die-changing process for a motor, pump, or other equipment … while leaving power on to the heating elements and computer controls.”

The Plastics Industry Association (formerly SPI) held a meeting in Chicago on Aug. 3 to discuss the rule change, with a follow-up conference call on Nov. 17. The association continues to work with area molders and MIOSHA.

MIOSHA noted in an Oct. 3 email from the Michigan Dept. of Licensing and Regulatory Affairs that it had mailed letters to approximately 1000 companies in the state classified under the NAICS 326 code (Plastics and Rubber Manufacturing), giving notice of the rule change.

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