January 12, 2021  
Department of Labor and Economic Opportunity  
MIOSHA, Technical Services Division, Standards and FOIA Section  
530 West Allegan Street  
P.O. Box 30643  
Lansing, MI 48909-8143  
Attn.: Toscha Klopp, via email: tklopp@michigan.gov  
Re: January 12, 2021 Public Hearing Comments for MIOSHA General Industry Safety and  
Health Standard Part 62. Plastics Molding  
Dear Ms. Klopp,  
The Plastics Industry Association (PLASTICS) thanks MIOSHA for advancing its process for  
proposed amendments to MIOSHA General Industry Safety and Health Standard Part 62.  
Plastics Molding (“Part 62”) to reflect current technologies used in the plastics industry.  
PLASTICS, formerly SPI, is the only organization that supports the entire plastics supply chain,  
representing nearly one million workers in the $451 billion U.S. industry. Our members include  
companies that operate plastics molding machinery in Michigan and companies that sell plastic  
molding machinery to them. PLASTICS is also an American National Standards Institute (ANSI)  
accredited standards developer.  
We remain grateful for and supportive of MIOSHA’s efforts to address the Part 62 requirement  
for a mechanical device on horizontal injection molding machines, as reflected in the current  
proposed amendments. Despite our efforts in this process, upon further reflection and input,  
members voiced concerns that requirements for safety circuits are unclear; that is, principles  
and requirements of relevant standards such as ANSI/PLASTICS B151.1-2017 are not  
sufficiently incorporated. We respectfully oppose parts of the proposed amendments to R  
408.16234, requesting new language in these comments to resolve this and further improve  
Part 62. We also request a definition in R 408.16207 to clarify the term “safety gate.”  
Request for Amendment Process – Background  
In July 2017, PLASTICS requested initiation of an amendment process to remove the  
requirement for a mechanical device on plastic horizontal injection molding machines (IMM) built  
on or after January 7, 2017. Our basis for the request, to amend R408.16234, included:  
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A thoroughly documented risk assessment, previously communicated to MIOSHA and  
conducted by one of the foremost internationally recognized experts in the application of  
risk assessment to machinery safety, determined the mechanical device to be  
1425 K Street NW, Suite 500, Washington, DC 20005  
P 202.974.5200 | plasticsindustry.org  
PLASTICS Comments - MIOSHA Part 62 Public Hearing  
January 12, 2021  
unnecessary for machines in compliance with ANSI/SPI B151.1-2007; that is, “removing  
the mechanical device does not impact the risk.”1  
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The 2017 edition of ANSI/PLASTICS B151.1 allows optional use of a mechanical device  
for horizontal clamp IMMs (but is still required for vertical clamp IMMs), built to the  
ANSI/PLASTICS B151.1-2017.2  
All machines, whether horizontal or vertical clamp IMMs, built prior to the 2017 ANSI  
approval date of ANSI/PLASTICS B151.1 (January 6, 2017), are required to have the  
mechanical device (drop bar/jam bar).  
Brazil is in the process of removing the requirement from its NR-12 standard3, leaving  
Michigan as the only known jurisdiction globally that requires this “redundant  
redundancy” on post January 6, 2017 built IMMs.  
Our initial proposal in March 2018 sought to incorporate ANSI/PLASTICS B151.1-2017 for  
horizontal clamp injection molding machines, either manufactured or modified to be compliant  
with that standard or any later version that provides equivalent reliability and protection.  
MIOSHA removed the reference to ANSI/PLASTICS B151.1 in its response, and it remains  
unclear why its adoption or incorporation was rejected.4 Since then, PLASTICS has worked with  
its members and MIOSHA to propose amendments that provide effective protection to workers  
performing certain activities and reflect current technology and standards for controlling  
hazardous energy sources.  
PLASTICS Requests to Further Improve MIOSHA Part 62  
A. PLASTICS requests the addition of the following definition for “safety gate” to R 408.16207:  
(3) “Safety gate” means a moveable, interlocked guard allowing the operator  
access to the point of operation to perform production related tasks.  
The existing definitions for “ship-lap machine” and “spin welding” would then need to be  
renumbered to (4) and (5), respectively.  
B. PLASTICS requests the following modifications to Rule 6234 (italicized strike/bold):  
R 408.16234 Injection molding machinery.  
Rule 6234. (1) An injection molding machine, except for one with a movable table that is  
subject to the provisions of subrule (4) of this rule, shall be equipped with a safety gate/ or  
guard that is designed and constructed to prevent an employee from reaching into the point  
1 “Analysis of Lockout as a Risk Reduction Measure for Mold Changes on Injection Molding Machines (IMMs)”,  
Prepared for SPI, August 2016. Communicated to MIOSHA on September 9, 2016.  
2 https://ansidotorg.blogspot.com/2017/02/ansiplastics-b1511-2017-safety-injection-molding.html#gref (last accessed  
January 5, 2021)  
3 Confirmed by the OSH Agency director at the ABIMAQ Conference in Sao Paolo, 3-5 April 2017.  
4 At least six MIOSHA General Industry Safety and Health Standards amended since March 2018 adopt by reference  
standards from organizations including ANSI: Part 6. Fire Exits (as amended June 11, 2019); Part 20. Underhung  
Cranes and Monorail Systems (as amended June 12, 2019); Part 63. Pulp, Paper, and Paperboard Mills (as  
amended April 11, 2018); Part 74. Fire Fighting (as amended June 14, 2019); Part 81. Baking Operations (as  
amended June 14, 2019), and Part 94. Textiles (as amended April 11, 2018).  
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PLASTICS Comments - MIOSHA Part 62 Public Hearing  
January 12, 2021  
of operation, except when the gate is open. For injection molding machines  
manufactured or remanufactured after February 6, 2008, the safety control systems  
provided shall be monitored to ensure proper function.  
(2) A safety gate on an injection molding machine that was manufactured after August 28,  
1973, shall be interlocked with electrical, mechanical, and hydraulic or pneumatic devices,  
except as noted in subrule (9) of this rule.  
(2) (3) AnA horizontal injection molding machine that was manufactured on or before  
August 28, 1973, shall have the safety gate interlocked to stop or prevent mold-closing by  
any 2two of the following:  
(a) An electrical mold-closing control.  
(b) Hydraulic, electric, or pneumatic valves thatpower control for mold closing.  
(c) A mechanical device that prevents mold closing.  
(d) A second electrical mold closing control (all electrical horizontal injection  
molding machines).  
(3) A vertical clamp injection molding machine shall have a mechanical restraint  
device to prevent unintentional gravity descent of the moldinjection unit, and shall  
have the safety gate interlocked to stop or prevent mold-closing by any 2two of the  
following:  
(a) An electrical mold closing control.  
(b) Hydraulic, electric, or pneumatic valves thatpower control for mold closing.  
(c) A second electrical mold closing control (all electrical vertical injection molding  
machines).  
We believe these modifications would further improve the proposed amendments. Regarding  
Rule 6234. (1), we believe monitoring is important; if a failure does occur, it will be known. The  
date specified in that sentence, February 6, 2008, was the compliance date for monitoring  
requirements in ANSI/SPI B151.1-2007. For what would be new Rule 6234. (2), for horizontal  
IMM, this would add clarity on the intent of the requirement, reduce confusion and underscore  
that two safety concepts/systems must be selected, encourage diversity in safety application,  
and eliminate the need for newly proposed option (d) by clarifying (b) to better convey our  
original intent. For what would be new Rule 6234. (3), for vertical IMM, this adds clarity by  
changing “injection unit” to “mold,” with parallel changes to (2) in the initial text, option (b), and  
elimination of newly proposed option (c).  
Without changes tracked, this section of Part 62 would then read:  
R 408.16234 Injection molding machinery.  
Rule 6234. (1) An injection molding machine, except for one with a movable table that is  
subject to the provisions of subrule (4) of this rule, shall be equipped with a safety gate or  
guard that is designed and constructed to prevent an employee from reaching into the point  
of operation, except when the gate is open. For injection molding machines manufactured or  
remanufactured after February 6, 2008, the safety control systems provided shall be  
monitored to ensure proper function.  
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PLASTICS Comments - MIOSHA Part 62 Public Hearing  
January 12, 2021  
(2) A horizontal injection molding machine shall have the safety gate interlocked to stop or  
prevent mold-closing by two of the following:  
(a) An electrical mold-closing control.  
(b) Hydraulic, electric, or pneumatic power control for mold closing.  
(c) A mechanical device that prevents mold closing.  
(3) A vertical clamp injection molding machine shall have a mechanical restraint device to  
prevent unintentional gravity descent of the mold, and shall have the safety gate interlocked  
to stop or prevent mold-closing by two of the following:  
(a) An electrical mold closing control.  
(b) Hydraulic, electric, or pneumatic power control for mold closing.  
To show the difference between PLASTICS’ request and MIOSHA’s August 2020 document:5  
R 408.16234 Injection molding machinery.  
Rule 6234. (1) An injection molding machine, except for one with a movable table that is  
subject to the provisions of subrule (4) of this rule, shall be equipped with a safety gate or  
guard that is designed and constructed to prevent an employee from reaching into the point  
of operation, except when the gate is open. For injection molding machines  
manufactured or remanufactured after February 6, 2008, the safety control systems  
provided shall be monitored to ensure proper function.  
(2) A horizontal injection molding machine shall have the safety gate interlocked to stop or  
prevent mold-closing by any 2two of the following:  
(a) An electrical mold-closing control.  
(b) Hydraulic, electric, or pneumatic valves thatpower control for mold closing.  
(c) A mechanical device that prevents mold closing.  
(d) A second electrical mold closing control (all electrical horizontal injection molding  
machines).  
(3) A vertical clamp injection molding machine shall have a mechanical restraint device to  
prevent unintentional gravity descent of the mold injection unit, and shall have the safety  
gate interlocked to stop or prevent mold-closing by any 2two of the following:  
(a) An electrical mold closing control.  
(b) Hydraulic, electric, or pneumatic valves thatpower control for mold closing.  
(c) A second electrical mold closing control (all electrical vertical injection molding  
machines).  
Closing  
We believe the modified language and added definition will increase the clarity for safety circuit  
requirements and better reflect current technology and standards, resulting in an improved Part  
62. This would resolve our opposition to the current proposed amendments of these sections.  
5 2019- 122 LE GI Part 62 Plastic Molding (Strike and Bold) – 8-19-2020.pdf. This shows those changes accepted,  
with PLASTICS’ new request in strike/bold.  
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PLASTICS Comments - MIOSHA Part 62 Public Hearing  
January 12, 2021  
PLASTICS’ members remain committed to the safety of their workers, including the safety  
standards to which machinery is built and the safe operation, maintenance, and servicing of  
such machinery. We thank MIOSHA for the opportunity to participate in this process and  
appreciate your consideration of our requests. Please let us know if we can further assist.  
Sincerely,  
Marie Gargas  
Senior Technical Director, Regulatory Affairs  
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