Shut It Down, Make It Safe - The Control of Hazardous Energy Sources

Shut It Down, Make It Safe The Control of Hazardous Energy Sources and Horizontal Injection Mold Machines (IMM) Presented by:

Michigan Occupational Safety and Health Administration Consultation Education and Training (CET) Division Michigan Department of Licensing and Regulatory Affairs (LARA) www.michigan.gov/miosha (517) 284-7720

C U S T O M E R D R I V E N.

B U S I N E S S M I N D E D.

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Objectives • Discuss significant changes to Part 62. Plastic Molding as it pertains to injection molding operations. • MIOSHA Standard - Part 85. The Control of Hazardous Energy Sources and applicability to Horizontal Injection Molding operations. • Answer questions.



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Rule Change Affects Mold Changes How many were aware of changes? How many have took action for changes? What types of machines?



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How many received this letter dated 9/14/2016?



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Part 62 Changes Rule 6234 Injection Molding Machinery Previously Rule 6234(10) provided an alternate procedure for routine mold changes on horizontal IMM's when the machine met certain requirements outlined in either subrules (a) or (b). Alternate Procedure – Activate the emergency stop or other stop and lock the operator door (a) or the rear barrier (b) in the open position.



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Part 62 Changes New Rule 6234 Injection Molding Machinery Rule 6234(10) Mold changes on horizontal plastic IMM's may continue to be conducted using [alternate] procedures specified in subrule (11) through December 31, 2016. Effective January 1, 2017, employers engaged in mold changes on horizontal IMM's shall comply with Part 85 “The Control of Hazardous Energy Sources.”



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Part 62 Rule Changes Rule 6234 (11) An employer shall ensure that routine mold changes on a horizontal IMM are conducted in accordance with either of the following if the machine has an interlocked safety gate that complies with subrule (2) of this rule and an electrically interlocked barrier covering the mold area opposite the operator:



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Part 62 Rule Changes Rule 6234 (11) (a) On a horizontal IMM that has a functional mechanical safety device plus two independent interlocks on the operator's gate and an emergency or other stop which shuts off the motor or motors which activate the clamping mechanism, the person changing the mold shall activate the emergency or other stop and lock the operator's gate in the open position. An employer shall ensure that the interlocks are checked and found to be functional and properly adjusted before beginning the mold change.



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Part 62 Rule Changes Rule 6234 (11) (b) On a horizontal IMM which has two independent interlocks on the rear barrier that shut off the motor or motors that activate the clamping mechanism, the person changing the mold shall lock the rear barrier in the open position. An employer shall ensure that the interlocks are checked and found to be functional and properly adjusted before beginning the mold change.



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Rule Change Affects Die Changes Part 62 Lockout as allowed until January 2017



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Part 62 Changes Reasons for the standard change: - MIOSHA standards are required to be at least as effective as federal standards. - Review of the MIOSHA standard by OSHA indicated that this alternate procedure was not acceptable for the following reasons: - lack of control reliability. - lack of definition of routine mold changes. - changing of molds on IMM is a service and maintenance activity and falls into the scope of 1910.147, MIOSHA Part 85 Lockout/Tagout (LO/TO).



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Part 62 Changes Reasons for the standard change: Part 62. Plastic Molding was evaluated to determine if the standard was at least as effective as federally established standards, primarily 1910.147 The Control of Hazardous Energy. The evaluation recommendation was to update Part 62 to better reflect the requirements, applications, and interpretations of Federal OSHA standards and industry practices. The Part 62 advisory committee ultimately concluded the procedures for horizontal IMM's [R408.16234 (11)] should be removed.



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Part 85 Applies When: Employees are performing service and maintenance activities, and there is a potential for injury from unexpected start-up or release of stored energy that could cause injury to employees. MIOSHA Training Institute (MTI) has upcoming classes for the Control of Hazardous Energy Sources: Midland, MI – June 6, 2017



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Selected Part 85 Definitions Normal Production Operations - Utilization of a machine or equipment to perform its intended production function.

Servicing and/or Maintenance - Constructing, installing, setting up, adjusting, inspecting, modifying, maintaining/servicing, lubrication, cleaning, unjamming, adjustment, or tool changes.



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MIOSHA Fact Sheet – Part 62 Complying with Rule Changes • Michigan businesses currently using horizontal IMM's must phase out procedures that currently allow for either the front or rear gates of the horizontal IMM's to be locked in the open position during die changes by December 31, 2016. • Beginning January of 2017, it is required that employers follow also the new rule requirements of Part 62 Plastic Molding in order to reduce hazards and eliminate possible accidents during die changes.



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MIOSHA Fact Sheet – Part 62 Resources and Recommendations – • While compliance with voluntary consensus standards for safety requirements for horizontal IMM's are not enforceable by MIOSHA, they can be used as guidance to reduce safety risks. •

• MIOSHA recognizes that older, pre-2000 model IMM's in use today along with some newly purchased machines may not be able to follow the current Part 85 Lockout standard without shutting down the heat system of the machines that controls the plastics’ temperatures.



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MIOSHA Part 62 FAQ Sheet Question 7 – Q7: We need to maintain heating elements and computer controls during die changes. How do we do that if we LO/TO during maintenance and servicing activities? A7: MIOSHA recognizes the need to maintain energy to heating bands and computer (PLC). 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, where employees are exposed to a hazard, while leaving power on to the heating elements and computer controls.



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MIOSHA Fact Sheet – Part 62 Resources and Recommendations – It is recommended that Michigan businesses who currently use horizontal IMM's and that may meet the above mentioned information, establish and utilize new die change procedures, and provide new training and instructional procedures for these horizontal IMM's. This will ensure that the full requirements of Part 85 Control of Hazardous Energy Sources Safety Standard is being used and understood by all employee operators and responsible die setting personnel.



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MIOSHA Fact Sheet – Part 62 MIOSHA Enforcement Policy – On December 31, 2016 the alternate mold change procedures [R408.16234(11)] for horizontal plastic IMM's in Michigan will expire. Effective January 1, 2017 the MIOSHA General Industry Safety and Health Division will begin enforcing the existing lockout provisions of Part 85 Control of Hazardous Energy Sources safety standard for all horizontal IMM die changes.



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* Lockout Options * 1.

Isolate hazardous energy sources.

2.

Most, but not all, machines tie energy sources together.

3.

You may separate hazardous energy sources from those that are not hazardous.

4. Requires some engineering changes to the wiring. 5.

All portions of lockout apply including verification of isolation.



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MIOSHA Part 62 FAQ Sheet Question 8 – Q8: If we follow the American National Standard on the Control of Hazardous Energy - LO/TO and Alternative Methods (ANSI/ASSE Z244.1) are we in compliance with the LO/TO requirements of Part 85? A8: No. Computer-based controls of hazardous energy (e.g. mechanical, electrical, pneumatic, chemical) conflict with the existing MIOSHA/OSHA LO/TO requirement.



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Components of an Energy Control Program under Part 85

1.

Energy control procedures

2.

Employee training

3.

Periodic inspection



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Energy Sources Found in Injection Molding • • • • • • •

Electrical Mechanical Hydraulic Chemical Pneumatic Thermal Gravity



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Widow files wrongful death lawsuit after husband crushed to death GRAND RAPIDS, Mich. — The widow of a factory worker who died while cleaning machinery has filed a wrongful death lawsuit against Grand Rapids Plastics Inc., claiming unsafe equipment and inadequate training led to his death in June, 2014. Russel J. Scharenbroch, a father of six, was fatally crushed while cleaning an IMM at the Wyoming plant. The lawsuit was filed in Kent County Circuit Court by Angel L. Scharenbroch and seeks more than $25,000 in damages. Grand Rapids Plastics encouraged employees to “act in accordance with putting more importance on the desire for profit over the safety of employees,’’ the lawsuit claims. Scharenbroch on June 27, 2014 climbed inside the machine to begin cleaning between two large steel molds. The machine was in auto mode at the time, meaning it was ready to operate, according to the lawsuit. A team leader, unaware Scharenbroch was inside, instructed a technician to start the machine. The molds were brought together, crushing Scharenbroch. The 34-year-old Morley man was pronounced dead at 5:17 p.m.



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Widow files wrongful death lawsuit after husband crushed to death Grand Rapids Plastics “had actual knowledge that an injury was certain to occur’’ and willfully or intentionally disregarded that knowledge on several fronts, the lawsuit claims. It did not equip the machine with a safety gate to prevent an employee from entering the point of operation and failed to develop lockout procedures for IMM's. Employees were allowed to enter the mold area of the machines without first locking out the power source, the lawsuit claims. Workers were not adequately trained in lockout procedures and there was no system in place to confirm there was not a worker inside the IMM before it was turned on, the lawsuit claims. Intentional acts and omissions by the company led to Scharenbroch’s death, the lawsuit claims. In an earlier interview with the Detroit Free Press, Angel L. Scharenbroch says she can't understand why no one saw her 6-foot, 200-pound husband inside the machine before someone turned it on, crushing him to death. "Emotionally it’s been a nightmare for myself and my children," she told the newspaper. The Michigan Occupational Safety and Health Administration in April, 2015 assessed the company $558,000 in penalties, but that amount was later reduced. Grand Rapids Plastics ended operations at its Wyoming plant in April. The company began layoffs after losing contracts with Fiat Chrysler, its main customer. It made parts for the Chrysler 200. Detroit Free Press



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Thank You For Attending Michigan Occupational Safety and Health Administration Consultation Education and Training Division 530 W. Allegan Street P.O. Box 30643 Lansing, MI 48909-8143 For further information or to request consultation, education and training services, call (517) 284-7720 or visit our website at www.michigan.gov/miosha.



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Shut It Down, Make It Safe - The Control of Hazardous Energy Sources

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