The Plastics Industry Association continues its push to amend a Michigan standard that calls for a mechanical device on horizontal injection molding machines manufactured after Aug. 28, 1973.
The Michigan Occupational Safety and Health Administration, or MIOSHA, passed a requirement for the state's injection molding companies to update safety procedures on their presses during mold changes effective Jan. 1, 2017.
The trade group's proposed changes reflect current technologies used by plastics processors and avoid "redundant redundancy," Marie Gargas, technical director of regulatory affairs for the plastics association, told a MIOSHA panel during a Jan. 12 virtual public hearing.
The group also would like the standard to be amended with a definition of a safety gate, she said.
The plastics association advocates for Michigan molders that operate about 450 manufacturing plants with an average of 30 injection molding machines as well as the equipment manufacturers.
Gargas addressed requested amendments regarding "General Industry Safety and Health Standard Part 62 Plastic Molding" (Part 62). No one else from the public spoke at the hearing or submitted written comments. But representatives listened in from injection molding machine builders Arburg USA, Engel Machinery Inc., Absolute Haitian and KraussMaffei Technologies.
Also, a manager at U.S. Farathane LLC, an Auburn Hills, Mich.-based automotive molder with eight factories in Michigan, is listed as a member of the Part 62 advisory committee.
Currently, MIOSHA says Michigan processors, when doing mold changes on a horizontal press, must have mechanical safety plus two independent interlocks on the operator's gate, or rear barrier, if that is being used, as well as an emergency stop to shut down the motor that activates the clamping mechanism.
The plastics trade group said the mechanical device should still be required for vertical injection molding machine, but it is urging MIOSHA to be more consistent with the American National Standards Institute when it comes to horizontal presses.
The association says it formally asked MIOSHA for the amendment process to be initiated in July 2017. To back up its request, the group pointed to the findings of a "thoroughly documented risk assessment," the 2017 edition of ANSI/PLASTICS B151.1, and steps being taken in Brazil to remove the requirement from its NR-12 standard.
The proposed amendment moved slowly and then was taken up by a MIOSHA labor and management committee in December 2019. Progress has been made to amend the standard, but the plastics association and its members still see room for improvement.
Gargas told MIOSHA officials, "Despite our efforts in this process, upon some referred further reflection and input, members voiced some concerns that requirements for safety circuits are unclear in the current proposed amendments."
In particular, some principles and requirements of ANSI/PLASTICS B151.1-2017 haven't been sufficiently incorporated, Gargas said. The trade group will submit new language to further clarify the proposal and improve Part 62, she added.
Gargas also requested a definition to clarify the term safety gate. The trade group would like it to say "safety gate means a movable, interlocked guard allowing the operator access to the point of operation to perform production-related tasks."
The trade group's request to amend the requirement for a mechanical device on plastic horizontal injection molding machines is based on a risk assessment that was shared with MIOSHA, Gargas said, and conducted by "one of the foremost internationally recognized experts" in the application of risk assessment machinery safety."
Michigan is one of only two jurisdictions worldwide that has this standard language, Gargas also said.
"As we have pointed out, Brazil is also in the process of removing the requirement for mechanical device from [its standard], which will ultimately leave Michigan as the only known jurisdiction globally that would require this redundant redundancy," Gargas said.
The hearing was over in 14 minutes. A MIOSHA staff member said Gargas' comments will be put into a report that will be reviewed by the state administrator's legal team, which will then make its recommendations about amending the proposal.