PRINTING United Alliance Supports Gestamp’s Variance Request from Lockout/Tagout Standard

PRINTING United Alliance submitted comments supporting Gestamp West Virginia’s (Gestamp) request for a variance from OSHA’s Lockout/Tagout Standard. Prior to OSHA granting a variance from one its standards, it must make a public announcement about it, provide its rationale, and share all supporting documents. PRINTING United Alliance supported the variance request to the similarity in equipment operation between Gestamp and newer equipment being utilized in printing operations.

Gestamp makes parts for the automotive industry. Gestamp uses a Trumpf laser cell to trim excess metal from automotive parts and burn holes into those parts. Gestamp requested a variance from the provision of the standard that requires all energy isolating devices needed to control the energy to the machine or equipment shall be physically located and operated in a manner as to isolate the machine or equipment from the energy source(s). Gestamp explained the need for the variance as follows: 

Without frequent cleaning, the laser system would not function properly. 

Frequent powering down and locking out of the laser greatly reduces the performance and overall life of the laser because it takes anywhere from 30 minutes to several hours to power back up after being completely shut down, which reduces the efficiency of the laser.  

Powering down the laser to perform cleaning activities requires the addition of auxiliary lighting, which would introduce extension cords and portable lights, potentially creating tripping hazards in the cell as well as shock hazards.  

The primary electrical disconnects are not designed or intended for frequent cycling and would increase the risk of arc flash hazards to the employees. 

The variance to Gestamp was completely supported because they are relying upon a combination of a comprehensive engineered system and appropriate administrative procedures. The variance application by Gestamp illustrates the real conflict between the concepts embodied by OSHA’s Control of Hazardous Energy or Lockout/Tagout (LOTO) Standard found at 29 CFR 1910.147 and new manufacturing equipment that has incorporated advanced safety systems relying upon reliable control circuits. The LOTO Standard needs to be revised and modernized in ways that promote worker safety and the cost-effective use of control circuit systems in lieu of energy isolation without placing additional burdens on employers.  
 
The scenario as outlined by Gestamp’s variance application, with respect to the time required to deenergize and reenergize equipment and the fact that equipment is not designed to withstand this schedule of frequent energization and de-energization, is common in the printing industry. Our industry is experiencing a rapid growth in both the use of digital technologies and modifications to conventional equipment. In conventional equipment electrical computer driven systems are replacing more traditional mechanically driven systems with a new reliance on sophisticated computer driven controls. 

PrUA’s  comment letter referenced the Association’s earlier comments submitted to OSHA in August of 2019 in response to their Request for Information where the Agency was looking for input on several possible changes to the regulation that would recognize newer safety systems being integrated into equipment. PRINTING United Alliance lead a coaling of 16 other printing trade associations in the development and submission of the comments. 

For more information, please contact the Regulatory Affairs Team at govtaffairs@printing.org