Safety

Wayne asks: Is there any site online where I can get any further information on LOTO as it pertains to clearing jam ups in the corrugated box industry?

Doug answers:

The “clearing of jam ups” in the corrugated industry will forever be a debated topic, as there are many variables. As a rule of thumb, JKJ’s Risk Control Consultants send the message that the clearing of jam ups requires lockout/tagout, as it is required by OSHA more often than not. See the first link below for OSHA’s overall stance. For the corrugated and printing industries, jam ups are non-stop and a part of everyday business. Handling these situations need to be thought of from a safety standpoint first and then from a compliance standpoint.

Too many companies make a blanket statement that the clearing of jam ups is considered minor servicing (see 3^rd link below) and is excluded from LOTO. While some clearing tasks may be considered minor servicing, others may involve significant danger (see 2^nd link below).

If jam ups routinely occur at a particular piece of equipment or on a specific line, the task of clearing the jam should be fully analyzed to determine if it meets the minor servicing exemption. If so, it is essential that an alternate means of protection be determined, as stated in the interpretation letter (4^th link below). Although not required, it is recommended that that the assessment and alternate means be documented.

https://www.osha.gov/dts/osta/lototraining/hottopics/ht-relche-1-4.html (Normal Production vs. Minor Servicing)

https://www.osha.gov/news/newsreleases/region5/05042016-0 (Clearing Jam Accident)

https://www.osha.gov/dts/osta/lototraining/hottopics/ht-relche-1-2.html (LOTO Minor Servicing Exemption)

https://www.osha.gov/laws-regs/standardinterpretations/2003-06-11 (OSHA Interpretation Letter)

https://jkj.com/blog/risk-control-quick-tips-volume-2/(JKJ Risk Control Quick Tip)

Steve writes:

I received a letter that said:

“The Workers’ Compensation Insurance Rating Bureau of California (WCIRB) was proposing changes to classifications (contained in the California Workers’ Compensation Uniform Statistical Reporting Plan-1995) that apply to employers in your industry, and that these changes are consistent with established classification procedure and do not reflect any change to the application of the classification(s). The proposed changes have been reviewed and approved by the WCIRB’s Classification and Rating Committee and are reflected in the following report:

http://www.wcirb.com/sites/default/files/documents/161025_cr_minutes.pdf

The proposed changes to Classification(s) 4240 and 4243 can be found on page(s) 29 and 30.

Please be advised that the proposed changes will be reviewed by the WCIRB’s Governing Committee and be included in a Regulatory Filing that will be submitted to the Insurance Commissioner for consideration. Changes approved by the Insurance Commissioner will be effective January 1, 2018.”

Can you tell me more about the scopes?

Doug responds: The description of the Workers Comp class codes have changed a tad in CA. When the descriptions (called scopes)change, a broker or insured needs to be able to lobby, or argue for another class code. I have provided various class codes, and various rates for each class code.

If any member has follow up questions I am happy to help.

PROPOSED

PAPER OR PULPCARDBOARD STOCK MFG. – including card, bristol, paper, straw, fibre or leather board manufacturing 4239(1) : Pure Premium Rate: 6.83 – Effective 1/1/2017

This classification applies to the manufacture of paper and cardboard stock, including but not limited to tissue, filtration and copy paper, roofing paper and roofing felt. This classification also applies to the manufacture of cardboard products, including but not limited to filter pads, fiber pads and cellulose insulation.

The manufacture of wood fiber products shall be classified as 4239(2), Fiber Products Mfg. Pure Premium Rate: 6.83 – Effective 1/1/2017

The manufacture of non-corrugated cardboard boxes shall be classified as 4240, Box Mfg. – Pure Premium Rate $8.43 – Effective 1/1/2017

paper or cardboard – rigid, or 4243, Box Mfg. – paper or cardboard – folding. Pure Premium Rate: 5.42 – Effective 1/1/2017

The manufacture of corrugated fiber board containers or boxes shall be classified as 4244, Corrugated

Fiber Board Container Mfg. Pure Premium Rate: 5.46 – Effective 1/1/2017

BOX MFG. – rigid paper boxesor cardboard – rigid 4240 Pure Premium Rate: 8.43 – Effective 1/1/2017

This classification applies to the manufacture of non-corrugated rigid paper and cardboard boxes that are preassembled with glue, staples or other fasteners. This classification also applies to incidental printing in connection with paper or cardboard rigid box manufacturing operations. Box manufacturing operations performed in connection with other operations of the employer are a General Inclusion. See Section III, General Classification Procedures, Rule 5, General Inclusions.

The manufacture of folding non-corrugated paper and cardboard boxes that are shipped flat shall be classified as 4243, Box Mfg. – paper or cardboard – folding. Pure Premium Rate: 5.42 – Effective 1/1/2017

The manufacture of corrugated fiber board containers or boxes shall be classified as 4244, Corrugated Fiber Board Container Mfg. Pure Premium Rate: 5.46 – Effective 1/1/2017

The manufacture of paper and cardboard stock shall be separately classified as 4239(1), Paper or Cardboard Stock Mfg. Pure Premium Rate: 6.83 – Effective 1/1/2017

Paper or paperboard manufacturing shall be separately classified.

Information on LOTO

For CA ONLY: Workers Comp Class Codes