OSHA Proposes Changes to the Lockout/Tagout Rule and Recordkeeping Rule

On December 27, 2016, SGIA submitted comments to OSHA to oppose proposed standard revisions under its Standards Improvement Project- Phase IV (SIP-IV), which is designed to remove or revise outdated, duplicative, unnecessary, and inconsistent requirements in OSHA’s standards. Under SIP- IV, OSHA proposes to revise 18 standards, two of which would have a significant and negative impact on the printing industry. One of those revisions affecting our industry is OSHA’s attempt to remove the term “unexpected” from sections of the lockout/tagout standard (1901.147) which would change the standard to apply to any energization or start ups and not just unexpected start ups. While this seems to be a minor change of one word, it can in fact cause a technical and logistical problem for printers currently performing lockout/tagout and minor service activities. SGIA sees this proposal as a step backward and it will negate all of the efforts that have been put forth to create integrated safety systems and advancements in safety procedures. Further, OSHA has taken the position to try and harmonize standards between General Industry sectors and “shipyards” regarding the removal of the term “unexpected”. This effort has been pointed out by SGIA as inapplicable as the two sectors do not address the same practices or methods needed with regard to specific equipment and maintenance activities. The other revision of concern for our industry is the proposal to add a cross reference to the injury and illness recording keeping standard 1904.5 in paragraph section 1904.10(b)(6) regarding hearing loss.  Essentially this change was proposed to make the rule consistent with the OSHA’s guidance document. In reality, this change would extend to the employer the requirement for making a determination of whether a worker's hearing loss is work-related, with little or no consideration for any loss that may be the result of exposures outside the workplace. In other words, any contribution to hearing loss from work can make the case “work-related” In addition, the wording and vagueness of the revision regarding hearing loss would too easily negate any non-work related exposures by employees and potentially increase incidents that need to be recorded and increase the potential for OSHA inspections. SGIA will continue to monitor the progress of this proposed rule. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.