PLASTICS Urges Occupational Safety and Health Administration to Maintain Wording of Lockout-Tagout Standard 

The Plastics Industry Association (PLASTICS) submitted comments urging the Occupational Safety and Health Administration’s (OSHA) to retain the word “unexpected” in the term "unexpected energization" in the existing general industry standard for the control of hazardous energy, lockout/tagout (LOTO; 29 CFR 1910.147), in response to the agency’s Standards Improvement Project-Phase IV (SIP-IV) proposed rule. 

PLASTICS argued that the importance of the word “unexpected” is clear from its pervasive use in the standard, consistent with the industry consensus standard on which it was based, and the underlying principle of key federal court decisions known as GMC Delco – that LOTO is not required where reliable control circuitry provides effective protection to employees from the potential for “unexpected energization or start up or release of stored energy.” PLASTICS further argued that eliminating the word “unexpected” would be a material change to the standard, and a separate rulemaking should be pursued to update the standard to reflect current technological advances.

For more information, please contact Marie Gargas.