CIS' Innovative Partnership with Plastics Industry Eliminates an Economic Hardship and Protects Worker Safety

Agency: Licensing and Regulatory Affairs

MARCH 15, 2000 - Michigan Department of Consumer & Industry Services (CIS) Director Kathy Wilbur announced today that a partnership with plastics industry leaders will protect worker safety and the economic vitality of one of the state's leading industries.

CIS, which administers the MIOSHA program (Michigan Occupational Safety and Health Act), discovered that a federal Occupational Safety and Health Administration (OSHA) standard was having a severe economic hardship on the plastics industry, and in some cases was being ignored therefore creating a worker safety hazard. CIS took proactive steps to determine the extent of the hazard, make sure workers were protected, and develop a solution that would meet the needs of employees, the industry and government.

In 1993, OSHA promulgated a new lockout/tagout (LO/TO) standard, which was adopted by reference by MIOSHA in 1994. Lockout/tagout refers to the process of cutting off energy sources so that machinery remains inoperative during servicing or maintenance, which is vital to preventing countless fatalities and accidents.

It was only after the rule was enforced, that the plastics industry determined the new standard would impact the economic viability of plastics manufacturers, as well as present a serious risk to product quality during production operations, particularly mold changes. The new standard increased the time needed to change a mold (e.g., from 20 minutes to two hours) and the cooling of the molten resin during the lockout also affected the integrity of the resin. Because most molding machines are controlled by computers today, the lockout also had the potential to damage the machines themselves.


"What was alarming to CIS, was that workers were being placed in potentially dangerous situations because the industry apparently was not complying with the lockout standard," said Director Wilbur. "We decided it was imperative to find a solution to the plastics industry problems, while protecting Michigan workers."

Timothy Koury, Corporate Safety Director, Blue Water Plastics, was one of the leaders in a national effort to seek relief from federal OSHA. Koury asked MIOSHA and The Society of the Plastics Industry (SPI), Inc., an 1,800 member trade association, to help address the situation with the new LO/TO standard.

MIOSHA facilitated a meeting with federal OSHA and MIOSHA staff, SPI staff, and several Michigan plastics industry representatives, to address the key issues presented by the new LO/TO standard. After studying the issue, OSHA determined that to adapt the standard to allow for mold changes could compromise the standard applicability to processes in other industries. Thus efforts to achieve a national resolution to the problem were not successful.

As a member appointed by Gov. John Engler to the MIOSHA General Industry Safety Standards Commission, Koury was aware that MIOSHA has a Plastics Standard, Part 62, which OSHA does not. This standard prescribes certain safety requirements for Horizontal Injection Molding Machines (HIMM) and related operations. Koury, SPI, and other Michigan plastics manufacturers and union members, then approached MIOSHA to address the problem by amending the plastics standard. MIOSHA asked its Part 62 Advisory Committee to explore the possibility of amending Part 62.

This public/private-sector partnership was able to find a solution without diminishing the integrity of the applicability of the LO/TO standard. In the 25 years since Michigan first promulgated Part 62, plastics machinery has grown increasingly sophisticated. The mold machine is guarded by a barrier guard with interlocked gates on the front and rear. The Committee recommended an amendment to Part 62 utilizing the interlock system, that would allow a hasp to hold the interlock gates open and therefore eliminate the danger of unintentionally starting the machine.

The MIOSHA General Industry Safety Standards Commission reviewed the recommendation of the Committee, held public hearings, and then amended Part 62. The Amendment was filed with the Secretary of State 1/24/00 and became effective on 2/8/00.

The U.S. plastics industry employs 1.3 million workers and provides $274 billion in annual shipments. In Michigan, plastics shipments totaled $19.4 billion and the industry employed 95,000 in 1996. Michigan ranks third in plastics production in the nation, behind only California and Ohio.