FPA Submits Letter to OSHA Requesting to Reconsider and Modernize the Lockout/Tagout Standard

On behalf of the Flexible Packaging Association (FPA), representing manufacturers and employers in the flexible packaging and printing industry, we respectfully submit this letter to request that the Occupational Safety and Health Administration ("OSHA") reconsider and modernize the application of the Control of Hazardous Energy (Lockout/Tagout) standard, 29 CFR 1910.147 ("LOTO Standard"), as it pertains to machine set-up. This letter serves as a follow-up from our virtual meeting held on Friday, June 12, 2026, and is pursuant to OMB’s Request for Information, Docket No. OMB-2025-0003-0001, requesting information on regulations that should be repealed, rescinded, or reformed. These comments are exclusively focused on the area of occupational safety and health regulation. We ask that OSHA either deregulate, provide a clear regulatory exception for, or issue administrative guidance addressing the compliance gap that currently exists for set-up activities in printing and flexible packaging equipment that has occurred since 1989, when the current regulations were last updated.

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