The U.S. Court of Appeals for the Sixth Circuit ruled in favor of Sofidel America, reversing OSHA safety citations that were issued following a worker injury at the company's Ohio paper manufacturing facility. The Jan. 9 decision grants Sofidel's petition for review and overturns an earlier ruling by the Occupational Safety and Health Review Commission that had upheld the citations.
The case stems from an incident at Sofidel's paper-products factory in Circleville, Ohio, where the company manufactures toilet paper and other household products for major retailers including Costco. The injury occurred in the facility's converting department, where large rolls of toilet paper weighing several tons each are processed through unwinding, embossing, and rewinding operations to create finished consumer products.
According to court documents, the incident involved the R88 Rewinder, a large industrial machine used in the paper conversion process. The machine frequently experiences jams due to toilet paper's inherently low tensile strength, requiring regular maintenance interventions by factory workers.
When the R88 Rewinder jams, the machine automatically shuts down as a safety measure. To clear these jams, employees must enter the machine through what is described as an "interlock door." Opening this door is designed to deenergize the machine, though certain functions like the "jog function" remain operational for maintenance purposes.
Following the worker injury incident, the Occupational Safety and Health Administration conducted an investigation and subsequently issued multiple citations against Sofidel America for alleged workplace safety violations. The citations focused on safety protocols and procedures related to the operation and maintenance of the R88 Rewinder equipment.
Sofidel America initially contested the OSHA citations before the Occupational Safety and Health Review Commission, the independent federal agency that adjudicates disputes between OSHA and employers. However, the OSHRC upheld OSHA's citations in its initial ruling, prompting Sofidel to seek review from the federal appeals court.
The case was heard by a three-judge panel consisting of Circuit Judges Clay, Kethledge, and Larsen. Circuit Judge Kethledge authored the opinion for the Sixth Circuit Court of Appeals, which has jurisdiction over federal appeals from Ohio, Michigan, Kentucky, and Tennessee.
In granting Sofidel's petition for review, the Sixth Circuit effectively reversed the OSHRC's decision to uphold the OSHA citations. The ruling represents a victory for the Italian-owned paper manufacturer, which has operations across multiple states and supplies major retail chains with private-label paper products.
The decision highlights ongoing tensions between workplace safety enforcement and industrial operations, particularly in manufacturing environments where heavy machinery poses inherent risks to workers. Paper manufacturing facilities like Sofidel's involve complex equipment and processes that require careful balance between operational efficiency and worker protection.
Sofidel America is part of the larger Sofidel Group, an Italian-based tissue paper manufacturer with global operations. The company's Ohio facility represents a significant investment in U.S. manufacturing capacity, producing products for some of the country's largest retailers.
The case also underscores the multi-layered nature of workplace safety enforcement, involving initial OSHA investigations, OSHRC administrative proceedings, and potential federal court review. This structure allows employers to challenge safety citations through administrative and judicial channels when they believe enforcement actions are inappropriate or excessive.
While the Sixth Circuit's opinion was marked "not recommended for publication," indicating it may have limited precedential value, the decision nonetheless provides insight into how courts evaluate workplace safety disputes in industrial settings. The ruling may influence how similar cases involving machinery-related injuries and safety protocols are handled in the future.
The reversal of the OSHRC decision means that the OSHA citations against Sofidel America are no longer enforceable, potentially saving the company significant financial penalties that typically accompany such violations. However, the decision does not preclude OSHA from pursuing alternative enforcement actions if additional safety concerns arise at the facility.
For Sofidel America, the favorable ruling allows the company to continue its operations without the burden of contested safety violations while maintaining its role as a major supplier to national retail chains. The decision may also provide guidance for other manufacturers facing similar OSHA enforcement actions related to equipment maintenance and worker safety protocols in industrial environments.