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MAPP Plastics Discussion Forum

The MAPP Plastic Industry Discussion Forum allows members to rapidly communicate with each other. Post both questions and answers to questions that other MAPP members have about any industry topic from material and process issues to R&E Tax Credits and other business issues.

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Posted:  02 Mar 2012 00:54
Has anyone had experience with OSHA and a requirement to perform Lock Out/Tag Out on a press, during mold changes and clearing a jam?

More pointedly, if you have incepted an acceptable solution, to avoid a full shut down, I would like to have a confidential conversation with you. Please email or call Wayne 715.831.1682

Posted:  02 Mar 2012 01:49

We have had some experience with this either myself or my safety coordinator will be in touch with you.

Rick Cartuyvelles
Posted:  02 Mar 2012 02:17
We had extensive dealings with OSHA on this issue here in Ohio. Were able to give them a acceptable procedure that did not involve shutting the press down. It is simple and low-cost. I would be happy to discuss it with you.


James M. Brogden
10 Eagles Way
Piqua, OH. 45356
Phone: 937-564-0071

Jim Brogden
Posted:  02 Mar 2012 16:04
I would be very interested in knowing the procedures that are suggested to you. I am sure other MAPP members would too.  If it isn't too involved can you post the procedure here?  Or possibly share it with one of the MAPP staff who might be able to summarize and post.


Posted:  02 Mar 2012 17:51
Wow....I did not expect such a large reply! Not only on this post, but through emails and phone calls as well. I certainly appreciate everyone's assistance. Troy even called me and asked me to share the results of this issue.

Please do not misunderstand, we are committed to the safety of our most valueable assets, our associates. I am simply seeking a satisfactory solution that will make everyone happy and safe.

As soon as I get through this exercise, I will be sure to share what I have learned. Thanks again!!
Posted:  09 Mar 2012 23:10   Last Edited By: Interplex Plastics
You know what is so sad about this?  Your comment, "please don't misunderstand..."  I am dealing with an OSHA inspection for air quality and keep qualifying everything I say about OSHA with a comment about the importance of employee safety. It's like OSHA is the KGB and anything you say will be used against you, regardless of where and to whom it was said.  And OSHA does nothing to dispel their reputation as a bully regulatory agency.
I think for the most part the plastics industry is pretty safety conscious, especially those forward thinking enough to join in an industry group or trade association, like MAPP.  Good Luck.  This is  a frontline battle for all of us.  Full shut down because of a red light.  Sounds like one of those new inspectors with more training than common sense.
Posted:  23 Apr 2012 16:10
Dear MAPP Members:

Wayne Piltz just updated me on his Lock Out Tag Out issue with OSHA and has implemented the following solution.  I have copied and pasted the email he sent to me verbatium so if you have any questions, please send him a note through this forum:

Email From Wayne Piltz on 04/23/2012.....
As we have gone through this process, we have been able to reach an understanding with our local office.  They will allow a padlock to be installed through the front  door and rail, to physically prevent the door from closing, as the means of the redundancy they were seeking.

Their point was, the machine interlock could fail, so the power sources (both electrical and hydraulic) need to be isolated. The solution above was an acceptable abatement - to this office (this time) anyway.   

Then of course, the procedure and training for such, need to be documented and kept on file for review.

Thank you to yourself and the MAPP organization for allowing me to seek information, provide a platform to communicate with others and share solutions. Also, a big thanks to the several members who reached out on the blog (and phone calls) to offer suggestion. It has all been very helpful!  ......End of Email Communication from Wayne Piltz
Posted:  18 Jun 2014 23:29
Attention All MAPP Members:

I wanted to share with you a current situation of a MAPP member who has recently under gone a suprise visit from OSHA. 

Please, if any members have insight into this issue, I strongly incourage you to post any information you have as it may help the industry as a whole.

The MAPP Member in reference received a surprise OSHA visit in January that targeted Lockout / Tagout.  Four months later, the company received a citation because they did not power down and lock out the injection molding press during mold changeover.

The company has 21 injection molding machines, with 19 of them being all-electric machines and all less than ten years old. All meet current ANSI safety standards. In over 3,500,000 labor hours in their facility, they have never experienced a fatality or serious accident. It is their conviction that the redundant, ANSI approved safety-measures on the equipment are all that is needed during this process.

The company has paid the reduced fine and submitted corrective action, which included engaging the emergency stop button during the changeover process. However, the corrective action was actually denied by OSHA, and the company is currently waiting to hear if their request for an extension of the abatement date has been granted.

The company representative indicated that at no time during this process was the OSHA inspection officer or the assistant area director able to offer the company any direction on how to meet the standard, stating that “it is a grey area.”

The comapny's plan is to challenge the current OSHA standard that mold changeover and setup is part of maintenance and service. The comapny is more than willing to take legal steps to challenge the OSHA standard and is looking for any input that MAPP Members may have that may help the company present a case. They have engaged their corporate attorneys as well their Congressman on this issue. 

Again, if you have any information that may help the company please email me direct or post to this location.

Troy Nix
Posted:  23 Jun 2014 17:33
I have a simple / cheap solution that passed our inspectors requirement. I am available for a call if they desire.

Posted:  25 Jun 2014 20:45
We used a local University (USF) to help support our safety program. They were fully conversant with all matters osha, it was free and they gave me a letter that would help deter a surprise osha visit.
I was told the is nationwide and open to all small and medium establishments.
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