1. in What Work Processes Should OSHA Consider Allowing the Use of [A Safety System That Relies On] Control Circuit Type Devices

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PLASTICS’ RESPONSE TO THE SPECIFIC OSHA QUESTIONS CONTAINED IN THE RFI 1. In what work processes should OSHA consider allowing the use of [a safety system that relies on] control circuit type devices for hazardous energy control? Subject to the need to preserve the ability to continue to use current alternative measures that provide effective protection to employees, we generally support the position stated in the Notes to Section 8.1 of ANSI/ASSP Z244.1-2016. We believe alternative methods would be appropriate in the following situations (this list is not meant to be exhaustive): 1. When hazardous energy is required to be present to perform the task; 2. When lockout/tagout is not feasible or practicable; 3. When inherent hazards (e.g., thermal, radiation) cannot be controlled using lockout/tagout; 4. When energy is required to maintain equipment in a safe state; 5. When repetitive cycling of an energy isolation device compromises its safe function; 6. When the operation of a standard energy isolation device creates an additional hazard. 7. From now until the time (five to ten years out) when manufacturers/integrators/suppliers and employers/end users will know what machinery, equipment and process designs are required to support Alternative Methods and they will be integrated upon delivery -- Minor Servicing Activities and Routine Set Up Activities when a documented job safety analysis shows the alternative methods provide effective protection. 8. From the time (five to ten years out) when manufacturers/integrators/suppliers and employers/end users will know what machinery, equipment and process designs are required to support Alternative Methods and they will be integrated upon delivery -- When a documented risk assessment by a qualified individual or team shows the task can be performed with acceptable risk.

More specifically, we believe alternative methods would be appropriate in performing the following tasks (this list is not meant to be exhaustive):

1. jam clearing 2. make-ready 3. lubrication 4. tool changes 5. roll polishing 6. cleaning 7. adjustments 8. calibrations 9. set-up 10. die changing 11. inspection 12. taking measurements 13. taking samples 14. removing molded parts from the mold 15. any other Minor Servicing Activities 16. Basic machine maintenance, excluding any changes to live or potentially live circuits, where the control circuit effectively controls the relevant hazardous energy sources and is under the control of the person doing the work and protects them from any unexpected energy. For example, a machine roller could be replaced, but a motor could not be replaced using alternative measures.

2. What are the limitations to using control circuit type devices? Do they have specific weaknesses or failure points that make them unsuitable for hazardous energy control? A safety system that relies on safety control circuit systems that do not isolate the hazardous energy1 would not be appropriate where the required work involves exposure to hazardous energized conductors (a hazard covered by Subpart S) or where line-breaking is required. Otherwise, proper design using reliable components will effectively control the risk. Programmed devices and their behavior must be thoroughly tested and inspected on an established frequency based on manufacturer recommendations or experience of the owner to ensure a safe condition.

3. If OSHA were to allow the use of control circuit type devices or other methods to control hazardous energy, would your firm choose to use them? Why or why not? Do you anticipate that these devices would save your firm money? For example, would these devices simplify operations or maintenance? Are there fewer steps needed to implement the controls? How frequently do you employ some form of lockout/tagout system in your facility? First, we believe it is appropriate to make clear that (as recognized by Questions 14, 15 and 22, below) OSHA already permits and, to varying degrees, our members already use safety systems that rely on safety control circuit systems or other methods to control hazardous energy per: (1) the explicit exceptions for Minor Servicing Activities and Testing And Positioning Activities; (2) the established OSH Act exceptions for technical and economic infeasibility; and (3) the exemption from Section 1910.147 recognized by GMC-Delco and its progeny. Second, our members need to be able to continue operating on that basis. Third, our members would likely expand their use of safety systems that rely on control circuit devices if OSHA modified Section 1910.147 to explicitly authorize that expanded use. For

1 UL6420 Standard for Equipment Used for System Isolation and Rated as a Single Unit describes the use of control circuit devices to remotely operate energy isolating devices:

This standard applies to isolating equipment incorporating electromechanical contactors remotely controlled and monitored to provide remote isolation status indication with a defined integrity level. This equipment is intended for use as an additional isolating means on the load side of the required supply-disconnecting device and over current protection. This standard applies to isolating equipment that is to be used in circuits of which the rated voltage does not exceed 1000 Vac or 1500 Vdc.

example, many members have interconnected pieces of production equipment on a single electrical energy source. Where lockout/tagout is required, it means taking the entire line down. If the members can use safety control circuit systems to isolate areas of the equipment, it increases their ability to place subsystems in a safe state for maintenance while operating the remaining sections of the line. Another example is that members increase the productivity of their equipment by customizing aspects of the safety control circuit system program based on their specific needs. Implementing these changes sometimes requires stopping the production line, but keeping the safety control circuit system energized to make the changes. If the company could use a safety control circuit system to control hazardous energy sources during planned maintenance events, the machine could remain energized, which would allow modification of the program in parallel to the mechanical maintenance efforts and shorten the machine down time. We believe the continued and expanded use of safety control circuit systems in lieu of lockout/tagout enhances and would further enhance safety, productivity, and employee job satisfaction through greater reliance on engineering controls, convenient implementation of energy control measures, reduced downtime and reduced incentive to bypass safety systems. We illustrate the huge productivity benefits achieved through the use of safety control circuit systems rather than lockout/tagout in attached Appendix 1. Most of our members’ facilities perform LOTO at least daily, if not more than several times a day.

4. Are there any specific conditions under which the use of control circuit type devices would not be advisable? Yes, when work being done would impair the safety functions of the safety control circuit system and in the circumstances described in our response to Question 2.

5. When the Lockout/Tagout standard was originally drafted, OSHA rejected the use of control circuit type devices for hazardous energy control due to concerns that the safety functions of these devices could fail as a result of component failure, program errors, magnetic field interference, electrical surges, or improper use or maintenance. Have new technological advances to control circuit type devices resolved these concerns? How so? First, we respectfully submit that GMC-Delco and its progeny effectively hold that lockout/tagout (implemented with energy isolating devices) is only required when safety control circuit systems do not protect employees from unexpected energization, start up or release of stored energy. Second, Section 1910.147 was adopted in September of 1989 on the basis of 1970’s technology. Even in 1988, Appendix 1 of the British Code of Practice for Safety of Machinery, BS 5304:1988 describes the use of dual-control system interlocking with a self- checked cross-monitoring function. The reliability of control circuit devices and safety control circuit systems design has significantly improved since then as evidenced by numerous national (U.S.) and international consensus standards.

For example, some modern devices can self-diagnose fault states and incorrect wiring. Use of dual channel systems has provided redundancy in case of device or wiring failure. Programming software can place restraints on how the devices are configured. These developments have reduced the chances of a device failing without detection or being installed or set up incorrectly.

6. Are there issues with physical feedback for control circuit type devices? No, feedback issues have always been a design consideration for a control engineer, and this is a well understood area. Feedback devices have evolved to address the issues faced on machines and are reliable. With the basic redundancy requirements in safety circuits, any failure is detected. Usually there is a pilot light or other indicator informing of the safety status of the circuit.

7. What are the safety and health issues involving maintenance, installation, and use of control circuit type devices? Have you found that alternative safety measures themselves cause any new or unexpected hazards or safety problems? Please provide any examples if you have them. The largest issue is the complexity of the devices. If the devices are not installed and configured properly, they will not function as expected. Generally, this results in the system being inoperable. For example, a shorted wire for an E-stop pushbutton can be detected by the input card. Our members have not identified any devices that increase risk or introduce new hazards (e.g., crushing, entanglement, laceration) if the installation is well engineered.

8. Do control circuit type devices address over-voltage or under-voltage conditions that may signal power-off, power-on, or false negatives on error checking? There are devices to detect these conditions. Were control devices to be allowed as alternative measures to lockout/tagout, these devices could be utilized where applicable. In some cases, they are integrated into other components, such as motor drives, and those devices are already handling the condition. False negatives are addressed by redundant circuitry already common in safety control circuit systems. Safety relays and intelligent safety sensors are designed to self- monitor for these examples of voltage issues and fault to a safe state.

9. How do control circuit systems detect if a component of a control circuit device breaks, bends, or otherwise goes out of specification? How do the systems signal this to the exposed employee? Could these types of failures create a hazard while the system continues to signal that conditions are safe? It depends on the design of the system. Some devices are simple enough that a redundant circuit is enough (i.e., E-stop pushbuttons). Others are redundant through different devices, such as a limit switch paired with a positioning encoder or warning and error limit switches. When

redundancy is used, any deviation can be captured in the machine code and a programmed response initiated. Alarms detailing the condition can be presented to the operator or maintenance staff. Further detail of fault conditions may be included in the device by default, such as fault error codes in a drive or PLC. The programmed response to a loss of one of these signals is to prevent further operation of the machine.

10. What level of redundancy is necessary in determining whether a control circuit type device could be used instead of an EID? The generally applicable principle is that no single failure will result in a loss of the safety function.

11. Lockout/tagout on EIDs ensures that machines will not restart while an employee is in a hazardous area. How do control circuit type devices similarly account for employees working in areas where they are exposed to hazardous machine energy? The relevant safety control circuit system would be switched to a controlled mode and each employee working in an area where a hazardous energy source must be controlled would have exclusive control over a control circuit device that maintained the circuit in that state. Furthermore, the control circuit must be designed so that the machine could not be inadvertently activated. Additionally, systems that rely on control circuit devices have a lower failure rate than systems that rely on human-controlled EIDs. Therefore, the safeguarding of the machinery is improved with safety control circuit systems.

12. How do control circuit type devices permit an employee to maintain control over his/her own safety? The alternative method must provide the protected employee with exclusive control. That control could be achieved by proximity to a control circuit device, having a body part that blocks an interlocked guard in an open position while the employee is in the protected zone, or locking a control circuit device in the “off” position, with the employee being exposed being the only person who possesses the key (or the use of a lockbox for group lockout if multiple persons are exposed).

13. How do control circuit type devices permit employees to verify that energy has been controlled before beginning work in danger zones? How do the devices account for exposed employees before equipment is restarted? There is a broad range of measures that can be used. For electrically driven equipment, one could hit a stop button, open an interlocked or activate the E-stop circuit, push the reset/start button(s) with interlocked guard still open or the E-stop still activated and confirm the equipment did not

restart. For hydraulic and pneumatic equipment, one can check the pressure gauges and confirm an absence of hazardous pressure in the areas of concern.

14. Control circuit type devices have a number of claimed benefits compared to energy isolating devices, including workers’ greater willingness to use such devices, better efficiency, less downtime, and the lack of a requirement to clear programming on computer controlled devices. Are there any other benefits to using control circuit type devices? Are there certain situations where these devices are especially advantageous? For example, where machine tasks require frequent repetitive access, is the process faster and/or less physically demanding than applying mechanical lock(s)? See Appendix 1. In general, engineering controls are more reliable than the administrative control of lockout/tagout, which depends on the individual deciding to apply lockout/tagout and then properly implementing it. While the use of a safety control circuit system may also involve the administrative procedure of locking a control circuit device, an employee is more likely to use such a device because it is significantly more convenient and avoids the substantial delays and productivity losses associated with machine start-ups.

15. What other methods or devices, if any, are being used with control circuit type devices to control the release of hazardous energy, especially in cases where the control circuit devices are only used to prevent machine start-up? Are there control circuit type devices that require additional methods or devices to fully control the release of hazardous energy? What improvements to safety or health does the use of these devices or methods provide? Improvements to safety and health would result from the greater reliability of these devices and the greater likelihood that they will be used. In some situations, it may be necessary to use a combination of safety control circuit systems and lockout/tagout to control the gravitational energy stored in an elevated component.

16. What are the unit costs for installing and using control circuit type devices or other Alternative Methods of hazardous energy control? Are the costs of installing and using control circuit type devices or other Alternative Methods of controlling hazardous energy dependent on the capacity or efficiency of the devices? If so, please include details on the effects of capacity on these unit costs including the capacity of any equipment you use in your facility. Are these devices generally integrated into newly purchased machinery, or are they purchased and installed separately? What steps need to be taken, and how long do those steps take, for these systems to be engaged in a manner that fully protects workers from the release of hazardous energy? The unit costs are generally far lower and readily accepted when incorporated in the initial design and installation of a machine. Retrofitting machinery can be both challenging and

expensive. Some of our members have investigated the costs of retrofitting the electric power circuits to separate the power source to the resin heaters from the other components of injection molding machines so they could maintain power to the heaters while locking out power to the rest of the machine. One received a quotation for over $13,000, per machine, including parts and labor for manufacturer installation. Other quotations for separating machine control circuitry into two or three circuits – anticipated to be especially difficult for older machines requiring involvement of the original equipment manufacturer – range from $5,000 to $15,000 per machine. For newer machines, retrofits performed by the end user at their location were estimated to range from $3,500 to $5,000 per machine. If the manufacturer performs the retrofit at the user’s location, the estimated costs rise to $5,000 to $7,000 for parts and labor without considering loss of production while the retrofits are being performed.

17. What additional actions is your firm taking to protect workers when they are servicing machinery with control circuit type devices in order to meet OSHA’s Lockout/Tagout standard requirements? For example, does your firm purchase and use physical devices that you feel do not enhance worker protections but nonetheless are required by the OSHA standard? What are these items and how much do they cost? Please explain why you feel these items do not enhance worker protections. Our understanding is that the other primary element is training workers on what tasks may and may not be performed using safety control circuit systems in lieu of lockout/tagout.

18. The American National Standards Institute (ANSI), the International Organization for Standardization (ISO), and the International Electrotechnical Commission (IEC) all have standards that may be applicable to control circuit type devices. Should OSHA consider adopting portions of any ANSI, ISO, or IEC standard that specifies requirements for control circuit devices as part of an updated OSHA standard? Are there recommendations in the consensus standards that you choose not to follow? If so, please explain why. Are there any requirements in these standards that would impose significant cost burdens if OSHA were to include those requirements in a revised Logout/Tagout standard? Are there provisions of one consensus standard when compared to the others that you perceive as having lower costs to implement and use on a day-to-day basis while providing protection to workers that is equal to or greater than that provided by the other standards? If so, please explain. Our members support the basic principle that OSHA should permit control of hazardous energy sources by any method that provides effective protection to workers and that an appropriate risk assessment may be used to assess whether a particular alternative method provides effective protection to employees. An inconsistency in the language of ANSI/ASSP Z244.1 may be perceived to the extent that it might be read to establish lockout, which Z244.1 acknowledges to be a less preferable administrative control, as the required method of energy control, where feasible. There are also objections to a change in the OSHA LOTO Standard that would place the burden of proof on the employer to conduct the extensive, complex, in-depth analysis required to

7 demonstrate that the alternative control circuit method it has been using effectively for many years is as effective as lockout/tagout. This is an unrealistic and infeasible approach for existing equipment, especially if OSHA would proceed on the assumption that lockout/tagout, an administrative control, would be properly applied in every instance and not pose an arc flash hazard. At some future time, when the criteria for safety control circuit systems used to implement alternative control measures have been established by OSHA and incorporated into machine designs by their manufacturers, the employer/user will be in a position (as is currently the case in the EU) to pass on the manufacturer’s representations and, based on those representations, demonstrate compliance with the OSHA design criteria for safety control circuit systems being used as an alternative means of controlling hazardous energy. The use of risk assessment is well established in the EU because The European Framework Directive on Safety and Health at Work (Directive 89/391 EEC) requires risk assessment to address hazards in the workplace and The New Machinery Directive2 that applies to equipment manufacturers and creates a presumption of compliance with the Directive if the manufacturer complies with the associated consensus standards applicable to its equipment and places a CE mark on the equipment.

19. ISO categorizes “the ability of safety-related parts of control systems to perform a safety function under foreseeable conditions” into one of five levels, called performance levels. These performance levels “are defined in terms of probability of dangerous failures per hour.” Should OSHA consider requiring a specific performance level in determining whether a control circuit type device could be a safe alternative to an EID? OSHA could reasonably set performance specifications per those standards for new equipment placed in service after a specified date that allows for the integration of the new design criteria into new equipment offerings with the expectation that the equipment manufacturers would have or retain the personnel qualified to develop compliant equipment designs. For existing equipment, many of our members would not have the personnel on staff qualified to perform such an evaluation, and may not have the electrical diagrams/schematics and performance specifications for the system and components necessary to perform that type of analysis. We also believe it would be unrealistic to require employers to disassemble equipment in an attempt to gather that information. To the extent that “legacy equipment” (any equipment that predates the compliance deadline under a revised OSHA LOTO Standard) features designs that do not comply with the level of safety performance/reliability standard that may eventually be adopted by OSHA, employers must be permitted to continue to use current alternative control measures with that “legacy” equipment as long as they provide “effective protection” as that phrase has come to be understood.

2 DIRECTIVE 2006/42/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006 on machinery, and amending Directive 95/16/EC (recast)

20. Can System Isolation Equipment, as discussed in the UL consensus standard UL6420 Standard for Equipment Used for System Isolation and Rated as a Single Unit, provide protection equal to that obtained through lockout/tagout? We are not familiar enough with that standard to provide a definitive comment on the reliability criteria. In principle, properly designed control circuits that remotely operate energy isolating devices, rather than relying on manual isolation by human beings, would be expected to provide greater reliability than manual lockout. However, the question appears to focus on an inappropriate premise. The question should be whether the risk has been reduced to an acceptable level rather than whether it can be reduced toward zero with this presumably expensive technology, which ultimately relies on control circuits. We would expect the costs of retrofitting an existing facility to be enormous and not justified on the basis of a risk assessment. To the extent that sites rely on solenoid valves to isolate pneumatic lines and dump the air pressure downstream of the valve, this concept is already in use.

21. The ANSI/ASSE Z244.1 consensus standard encourages the use of risk assessment and hazard control hierarchy as Alternative Methods of hazardous energy control. Should OSHA consider incorporating these methods in any new standard with respect to the use of control circuit type devices? For the reasons previously stated, other than the primary status of lockout/tagout in Z244.1-2016, our members generally support the principles presented in Z244.1 with respect to new equipment with the expectation that equipment manufacturers, with input from users, will design and deliver equipment designed to meet the criteria set out in Z244.1 and the modern reliability standards. However, we question whether it is feasible to apply that standard to existing equipment or to eliminate the Minor Servicing Activity exemption. Furthermore, we believe existing practices that rely on safety control circuit systems provide adequate protection to employees.

22. Do you currently utilize the services of a specialized safety engineer or employment safety administrator to test for competency and/or ensure that the hazardous energy control system is operational? If so, how many hours does this individual spend on these tasks? Do you anticipate you would need to make use of these services if OSHA revised the Lockout/Tagout requirements to align with the consensus standards? Based on data from the Bureau of Labor Statistics, OSHA estimates that an occupational health and safety specialist makes $33.14 an hour or $68,930 annually plus benefits. If you have used the services of such specialists, how does this compare with your experience? Only our larger members would have in-house expertise at the level that would be required (e.g., controls engineer) to implement the process described in ANSI/ASSP Z244.1 and methodologies such as those in ISO 13849 and IEC 62061. Most members would have someone with sufficient

technical and manufacturing knowledge and experience to perform a job safety analysis, which consists of:

• selecting the job to be analyzed • breaking the job down into a sequence of steps • identifying potential hazards • determining preventive measures to effectively control these hazards

23. How much training do you currently provide on Lockout/Tagout requirements? How long does training on this subject take and how often do employees receive training on the subject? If OSHA were to revise the Lockout/Tagout standard to permit use of control circuit type devices in some circumstances, would newly hired workers require more training or less than under the current standard? What format do you use to provide training on the Lockout/Tagout standard at your facility (i.e., small group classroom session, self-guided computer modules, etc.)? If you have used third-party training vendors to provide similar training, what are the costs? If training is provided in-house, what sort of employee provides the training (i.e., a first-line supervisor, a safety and health specialist, etc.)? Not addressed.

Questions 24 through 30 on Robots – Not addressed.

Specific Questions Regarding Economic Impacts. 31. Please describe in detail how a standard for the control of hazardous energy that incorporates the use of control circuit type devices or new robotic technology could create more jobs; eliminate outdated, unnecessary, or ineffective requirements; or produce other economic benefits. Please provide information supporting your view, including data, studies and articles. See Appendix 1.

32. The Regulatory Flexibility Act (5 U.S.C. § 601, as amended) requires OSHA to assess the impact of proposed and final rules on small entities. OSHA requests comments, information, and data on how many and what kinds of small businesses, or other small entities, in general industry employment could be affected if OSHA decides to revise provisions in 29 CFR 1910.147. Describe any such effects. Where possible, please provide detailed descriptions of the size and scope of operation for affected small entities and the likely technical, economic, and safety impacts for those entities.

See Appendix 1.

33. In addition, are there any reasons that the benefits of reducing exposure to hazardous energy might be different in small firms than in larger firms? Are there any reasons why the costs for controlling hazardous energy would be higher for small employers than they would be for larger employers? Are there provisions that would be especially costly to small employers? Please describe any specific concerns related to potential impacts on small entities that you believe warrant special attention from OSHA. Please describe alternatives that might serve to minimize those impacts while meeting the requirements of the Occupational Safety and Health Act of 1970, 29 U.S.C. 651 et seq. Small employers generally do not have in-house expertise. To the extent that small employers might be inclined to retain equipment for a longer period of time than large employers or acquire second-hand equipment, performing appropriate risk assessments and any modifications are anticipated to be relatively costly; therefore, employers should be permitted to continue to use alternative control measures with that “legacy” equipment as long as they provide effective protection.

APPENDIX 1 Economic Advantage of Relying on Safety Control Circuits Rather Than Lockout/Tagout to Control Hazardous Energy We asked our members to provide examples of maintenance and servicing activities where the use of safety control circuit systems rather than lockout/tagout provided significant economic (productivity) benefits, with supporting data. Their responses are incorporated into the following.

A. Typical Difference in Productivity for Mold Changes Under LOTO Versus Reliable Control Circuitry

One group of tasks universally identified by our members as falling into this category involves set up activities, such as changing the molds on a horizontal and vertical injection molding machines. Our members provided us with data on the time required to perform a mold change on a horizontal or vertical injection molding machine under LOTO versus reliance on cost-effective safety control circuit systems, and assess the economic consequences. Based on that member input, we estimate that, on average:

1. It would take an additional thirty minutes of machine down time to perform a mold change under LOTO if application of LOTO did not shut down the heaters that keep the plastic resin in a molten state; and 2. It would take an additional sixty minutes of machine down time to perform a mold change under LOTO if application of LOTO shut down the heaters that keep the plastic resin in a molten state.

Our members also provided us with data from which we can estimate the potential economic consequences of requiring LOTO rather than allowing reliance on cost-effective safety control circuit systems when performing mold changes. The estimate is based on member data that supports the following conservative assumptions:

1. Injection molders perform two mold changes per machine per week; 2. Each injection molder has 30 horizontal and/or vertical injection molding machines; and 3. Revenue loss for injection molding machine down time is $60 per machine per hour 4. The additional time required to produce the product under LOTO does not result in the loss of orders but does result in additional production time to fulfill the orders under LOTO (additional costs).

Based on those assumptions, the estimated average annual loss of revenue, per molder, in applying LOTO rather than relying on effective safety control circuit systems would be:

1. Approximately $93,500 if application of LOTO did not shut down the heaters that keep the plastic resin in a molten state; and 2. Approximately $187,000 if application of LOTO shut down the heaters that keep the plastic resin in a molten state.

There are tens of thousands of pieces of equipment that need power to perform mold changes for injection molding, thermoforming, rotary wheel blow molding, etc. As an example, in a previous exercise we estimated that there are approximately 450 facilities that operate an average of 30 injection molding machines in Michigan. Based on the foregoing analysis, the estimated average annual loss of revenue for all injection molders in Michigan, in applying LOTO rather than relying on effective safety control circuit systems would be:

1. Approximately $42,120,000 if application of LOTO did not shut down the heaters that keep the plastic resin in a molten state; and 2. Approximately $84,240,000 if application of LOTO shut down the heaters that keep the plastic resin in a molten state.

The underlying data for the mold change is provided in the following table.

Mold change comparison

As Currently Performed Using Control Circuits vs. Lockout/Tagout (Energy Isolation) Water and hydraulic connections have been prepared with fast disconnects.

As mold changes Applying are done LOTO Steps now [min.] [min.] purge material 5 5 open mold and move ejector forward to release tension (for uncoupling) 1 1 shut down machine / lock out tag out 1 remove ejector coupling 5 5 remove lock out tag / start machine (wait for control to start up) 5 close door / Close mold 0.5 0.5 shut down machine / lock out tag out 1 open door / Fix lifting fixture and safety mold bracket / attach mold to lifting device 3 3 remove clamps on movable platen 5 5

13 remove (water connections, core pull connections, hot-runner connections, valve gate connections, air connections…) 5 5 remove lock out tag / start machine (wait for control to start up) 5 close door / move movable platen back 1 1 shut down machine / lock out tag out 1 open door / remove clamps on fixed platen 5 5 lift mold out of machine 5 5 lift new mold into machine and fix mold clamps on fixed platen 12 12 remove lock out tag / start machine (wait for control to start up) 5 close door / close clamp 0.5 0.5 shut down machine / lock out tag out 1 open door and fix clamps on movable platen 7 7 remove lock out tag / start machine (wait for control to start up) 5 close door / open mold 0.5 0.5 move ejector forward 0.5 0.5 shut down machine / lock out tag out 1 couple ejector 3 3 additional works (water connections, core pull connections, hot-runner connections, valve gate connections, air connections…) 5 5 remove lock out tag / start machine (wait for control to start up) 5 wait for heats to come up (including screw protection time) 30 load mold recipe and adjust mold height if necessary 5 5 start production Total time in minutes 69 129 Loss per day in minutes 60 Loss per day in hours 1

B. Difference in Productivity for Mold Changes Under LOTO Versus Reliable Control Circuitry for Specialized Operations

In one example provided, if reliable, state-of-the-art safety control circuit systems could not be used and LOTO were required:

• The time to complete set-up tasks would increase by approximately 50% (directed cost around $400) • Temporary employees would need to be hired during peak time, resulting in: - Complicated logistics – e.g., training would first be required as machines vary in tonnage, process and automation. Specific training per machine, per person was estimated at $2000. - Retention costs during-off peak time (estimated at $20,000 to $40,000 during such periods annually) • Additional administrative tasks would be required; e.g., writing work instruction(s), writing specific alternative energy control procedures and (re)training employees • For manual machines, each machine would need to be locked out for 30-60 seconds every time a molded piece was collected • For large machines, extra safeguarding devices deemed necessary to safely perform the set-up have already been purchased and installed at costs ranging from $50,000 to $80,000 • Lost production per machine, per hour was estimated at $10,000 • This company estimated overall costs at more than $150,000

C. Difference in Productivity for Cleaning Plate or Anilox Cylinder on Flexographic Printing Press Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Control Circuit Required if Required if Time Per Frequency Measures Used to Use Control Apply Event if Apply of Activity Control Hazardous Circuit Energy Energy Per Day Energy Measures Isolation Isolation (minutes) (minutes) (minutes) Interlocked door on each printing deck or a common door for all decks, the nip point opens when door is opened, or 5 times/day 10 60 50 line stops and allows per machine anilox to turn at a slow speed (<5 feet/min). Cannot open door or guard while running.

D. Difference in Productivity for Cleaning Gravure Cylinder on Laminator Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Control Circuit Required Time Per if Use Measures Used to if Apply Event if Frequency of Control Control Hazardous Energy Apply Activity Per Day Circuit Energy Isolation Energy Measures (minutes) Isolation (minutes) (minutes) Nip guard, put in cleaning 5 times/day per mode, opens nip and turns 10 60 50 machine roll in opposite direction.

E. Difference in Productivity for Web Break at Unwind or Rewind on Laminator Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per if Use Frequency Control Circuit Measures Used to if Apply Event if Control of Activity Control Hazardous Energy Energy Apply Circuit Per Day Isolation Energy Measures (minutes) Isolation (minutes) (minutes) There is an interlock on door to access area; door will not open when Once/day machine is running. If door is open, 15 60 45 per machine cannot run. Once door is machine closed, machine must be reset to run.

F. Difference in Productivity for Changing Print and Anilox Cylinders on Flexographic Press Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per if Use Frequency Control Circuit Measures Used to if Apply Event if Control of Activity Control Hazardous Energy Energy Apply Circuit Per Day Isolation Energy Measures (minutes) Isolation (minutes) (minutes)

System is interlocked so it cannot run once interlocked guards are Not once per 45 NA opened (cannot do task if locked possible week out).

G. Difference in Productivity for Programming the Deck Positioning on a Flexographic Press Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per if Use Control Circuit Measures Used to if Apply Event if Frequency Control Control Hazardous Energy Energy Apply of Activity Circuit Isolation Energy Measures (minutes) Isolation (minutes) (minutes) With the selector switch in disabled it does not remove power but places the drives in INHIBIT. This position Not once per does not allow the drives to move 30 NA possible week the motors but does allow the drive to be programmed by qualified technicians.

H. Difference in Productivity for Unwind and Rewind Webbing on Winder or Fix Web Break on Blown Film Extrusion Presses (Rotogravure and Flexographic) Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per Control Circuit Measures if Use Frequency if Apply Event if Used to Control Hazardous Control of Activity Energy Apply Energy Circuit Per Day Isolation Energy Measures (minutes) Isolation (minutes) (minutes) There are several ways this works. There can be interlocked doors with CCD that has switches, light 4 to 5 curtains, scanners and safety times/day mats scanning the area. Each 15 60 45 on each of these will stop the line process from running, stop the turret from turning and stop the knife from firing once the CCD is interrupted.

I. Difference in Productivity for Turret Turning Over to Fix Web Break at Slitter/Roll Doctor Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per Control Circuit Measures if Use Frequency if Apply Event if Used to Control Hazardous Control of Activity Energy Apply Energy Circuit Per Day Isolation Energy Measures (minutes) Isolation (minutes) (minutes) Protected by light curtain or area scanner interlocked into 30 to 50 the stop system. Interlocked if times/day 5-10 20-30 15-25 in area or activate curtain. on each Has separate reset after process coming out of area

J. Difference in Productivity for Clearing Wrapping Unit Area Jam or Fixing Web Break on Pallet Wrapper Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per Control Circuit Measures if Use Frequency if Apply Event if Used to Control Hazardous Control of Activity Energy Apply Energy Circuit Per Day Isolation Energy Measures (minutes) Isolation (minutes) (minutes)

Interlocked light curtain stops 5 10 20 10 movement of roll wrapper times/day

K. Difference in Productivity for Programming the Robot at Material Packing Station Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per Control Circuit Measures if Use if Apply Event if Frequency Used to Control Hazardous Control Energy Apply of Activity Energy Circuit Isolation Energy Measures (minutes) Isolation (minutes) (minutes) Interlocked door - when door opens, system will not allow the reboot to operate. The maintenance technician has a pendant that is password Not Once per 10 NA protected that will allow the possible week robot to be programmed or troubleshoot. The technician has to be in the area to program the robot.

L. Difference in Productivity for Fixing Web Break on Rewinder on Flexographic Printing Press Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per Control Circuit Measures if Use if Apply Event if Frequency Used to Control Hazardous Control Energy Apply of Activity Energy Circuit Isolation Energy Measures (minutes) Isolation (minutes) (minutes) The gate at the rewind has a CCD that prevents the winder from moving (it E-stops the press) The gate has a flip Once/day down lock that does not allow 5 30 25 per the gate to close. Once the machine operator exits and closes the gate the press must be reset before the winder will work.

M. Difference in Productivity for Changing Sleeve on Flexographic Printing Press Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per Control Circuit Measures if Use if Apply Event if Frequency Used to Control Hazardous Control Energy Apply of Activity Energy Circuit Isolation Energy Measures (minutes) Isolation (minutes) (minutes) The Operator must change plate/anilox sleeves. Each machine safety guard has electrical locks; the consent to unlock each electrical lock Once/day is given if the machine is 2-3 10-15 7-12 per Stopped in Operator Stop machine Condition and the print unit is in Opening position. The torque and the speed of cylinders are limited in this mode. Drum does not move.

N. Mechanical Reset of the Deck on a Flexographic Press Under LOTO Versus Reliable Control Circuitry Lost Time Time Production Required Required Time Per Control Circuit Measures if Use if Apply Event if Frequency Used to Control Hazardous Control Energy Apply of Activity Energy Circuit Isolation Energy Measures (minutes) Isolation (minutes) (minutes) The machine must be stopped in Operator Stop mode. Several Activation is executed from times/year the main HMI. It is possible 30-60 180 120-150 per to interrupt the procedure at machine any time by pressing the arrest key.

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