Argent International Inc v. Mi Occupational Safety & Health Admin

CourtMichigan Court of Appeals
DecidedMarch 26, 2026
Docket367576
StatusUnpublished

This text of Argent International Inc v. Mi Occupational Safety & Health Admin (Argent International Inc v. Mi Occupational Safety & Health Admin) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Argent International Inc v. Mi Occupational Safety & Health Admin, (Mich. Ct. App. 2026).

Opinions

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

ARGENT INTERNATIONAL, INC., UNPUBLISHED March 26, 2026 Plaintiff-Appellant, 11:53 AM

v No. 367576 Ingham Circuit Court MICHIGAN OCCUPATIONAL SAFETY & LC No. 23-000171-AA HEALTH ADMINISTRATION,

Defendant-Appellee.

Before: O’Brien, P.J., and MURRAY and LETICA, JJ.

PER CURIAM.

Plaintiff, Argent International, Inc., appeals as on leave granted1 the circuit court’s order affirming the amended decision of the Board of defendant, Michigan Occupational Safety and Health Administration (MIOSHA), after it upheld two citations that were issued to Argent after one of its employees injured his arm in a press machine. The employee had been adjusting the way that a sticky material fed into the press by reaching beyond the press’s safety gate when the roller bar that was used to feed the material descended onto his arm. Argent provided safety blocks that would have prevented the roller bar from fully descending, but the use of the blocks was not outlined in the machine-specific guidelines that Argent had created for the press, and the employee was not using the blocks at the time he was injured.

After an investigation, MIOSHA issued two occupational-safety-related citations. The first citation (Instance A) was based on the employee’s failure to lockout the press before reaching beyond the gate to straighten the material. The second citation (Instance B) was based on Argent’s failure to identify or provide a control device for the gravity-related hazard in the press’s machine- specific procedures. On appeal, Argent challenges the legal basis for each citation and argues that

1 Argent Int’l, Inc v MI Occupational Safety & Health Admin, ___ Mich ___, ___ (2024) (Docket No. 167136).

-1- neither was supported by sufficient evidence. We affirm the circuit court’s order upholding the citations.

I. BACKGROUND

The Occupational Safety and Health Standards section of the Code of Federal Regulations requires an employer to control hazardous energy related to the servicing or maintenance of machines and equipment:

This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy. [29 CFR 1910.147(a)(1)(i).]

This section, which is also referred to as Part 85,2 requires an employer to establish a program and procedures to “affix[] appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start-up or release of stored energy in order to prevent injury to employees.” 29 CFR 1910.147(a)(3)(i). Although 29 CFR 1910.147 refers to lockout or tagout devices, the parties in this case address only lockout devices. A lockout device is “[a] device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in a safe position and prevent the energizing of a machine or equipment.” 29 CFR 1910.147(b). A lockout device prevents the machine from being operated until the device is removed. 29 CFR 1910.147(b).

The citations concerned Argent’s Sheridan press. Argent’s maintenance manager testified that the press handled multiple materials, which the roller bars fed into it from rolls. The front roller rose up out of the way when not in use, and if the rear roller was being used, the front roller would be in an upright position. A control panel existed specifically to operate the roller bar and gate. The supervisor of the injured employee testified that the materials used in the press are very sticky and sometimes need to be removed from the die. According to the supervisor, it was normal for materials to come out of alignment during production, and this occurrence happened daily and depended on the material’s shape and texture.

The supervisor and maintenance manager both testified that grabbing tools could be used to reach inside the machine. However, the supervisor testified that small adjustments could be made to line up the material by hand. The supervisor also testified that the operator was instructed to not put their hands behind the safety bar or under the roller bar, but safety procedures required blocks to be used to prevent the gate and roller bar from dropping down to prevent accidents or

2 The Administrative Law Judge, MIOSHA Board of Appeals, and the parties referred to 29 CFR 1910.147, Mich Admin Code R 408.18502, and Part 85 interchangeably. Because the Michigan Administrative Code has adopted 29 CFR 1910.147 by reference, we will simply refer to 29 CFR 1910.147 or Part 85.

-2- injuries to the operator’s hands when “some small adjustment” was required “with hands inside a little bit.”

MIOSHA initiated an investigation after one of plaintiff’s operators was injured while adjusting material that became crooked while he loaded it into the roller. The operator lifted the gate, reached in, and a roller bar came down onto his right forearm. The operator’s supervisor testified that the operator had probably been trying to perform small adjustments to the material. The supervisor testified that employees were instructed to use safety blocks when reaching beyond the gate to adjust material, but when the supervisor arrived, the safety blocks were on the floor. The injured operator later admitted that he had not used the safety blocks, even though they had been available.

After MIOSHA investigated the incident, it issued citations on the bases that Argent had not developed a machine-specific hazardous-energy control system for the gravity-related hazard in the die area of the press (Instance A) and that the press’s procedures did not identify or provide a control device for the gravity-related hazard in the die area (Instance B). At the hearings, the parties disputed whether the operator’s activities had constituted servicing or maintenance under Part 85, and if so, whether the operator’s activities fell within a minor-tool-change exception to the requirement to lockout the press. The Administrative Law Judge (ALJ) found that a preponderance of the evidence did not support finding that the operator’s activities met the definition of servicing or maintenance under Part 85. The ALJ found that, instead, the conduct fell within the minor-tool-change exception because the task was routine, repetitive, and integral to production. The ALJ also found that, when the press’s lockout procedures were followed, gravity caused the rollers to rest in the down position.

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Argent International Inc v. Mi Occupational Safety & Health Admin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/argent-international-inc-v-mi-occupational-safety-health-admin-michctapp-2026.