COMPLIANCE REFRESHER: LOCKOUT/TAGOUT
On their web site, OSHA recently posted two new interpretations clarifying
lockout/tagout procedures. Interpretations are answers to compliance
questions that employers submitted to OSHA in writing requesting
clarification of how the standard applies to their work situation. Interpretations
do not create new regulations or obligations.
Lockout/Tagout continues to rank high on OSHA's most frequently cited list
of standards. One of the goals of the lockout/tagout standard is to
prevent amputations and fatalities. Sudden start-up of machinery can cause
otherwise preventable amputations and gruesome fatalities. If you have
machinery that falls under OSHA's lockout/tagout standard, you should be
aware that OSHA's strategic plan focuses on reducing these types of
injuries. Lockout/tagout is prevention. If you are a high-risk industry,
you might be inspected and assessed high penalties if your program is
deficient. Better yet, be prepared and protect your employees. Take
a few minutes to read our compliance refresher.
The Federal Lockout/Tagout standard 1910.147, requires the adoption and
implementation of practices and procedures to shut down equipment, isolate
it from its energy source(s), and prevent the release of potentially
hazardous energy while maintenance and servicing activities are being
performed. It contains minimum performance requirements, and definitive
criteria for establishing an effective program for the control of hazardous
energy. However, employers have the flexibility to develop lockout/tagout
programs that are suitable for their respective facilities.
Employers should develop and implement a written electrical safety program.
Employers and employees should ensure that all electrical circuits are
de-energized and tested before working on or near them.
Employers should develop and implement an electrical lockout, tag-out
procedure for de-energizing circuits.
Compressors, production equipment, fans and any equipment with a missing
machine guard are the types of equipment that should be locked or tagged
out when being repaired. Equipment must always be locked when machine
guards are removed. and when anyone can put a hand, arm or head into the
machine or any dangerous area around a machine. The locks and tags should
be easy to recognize and contain the person's name who is authorized to
remove them.
Here are some examples of Servicing and Maintenance operations where the
1910.147 Lockout/Tagout standard would apply.
Printing Shop
In a printing shop, when a printing press is being used to produce printed
materials, there is often the need to make minor adjustments such as to
correct for paper misalignment while the press is running. This is a part
of the production process, and is subject to the machine guarding
requirements. The use of remote control devices which keep the employees
from reaching beyond the machine guards, or the use of inch (or jog)
devices that permit machine speed control for test purposes obviate the
need for lockout/tagout. However, printing presses may jam, requiring an
employee to bypass the machine guards in order to reach the area of the jam
and clear it. Although the need to clear the machine arises during normal
production operations, it is a servicing activity that involves employee
exposure to unexpected activation of the machine or release of energy, and
is covered under the Lockout/Tagout standard.
Plastic Sheet Application Machine
An employee is operating a machine that applies and seals a clear plastic
sheet around a packaged product. There is a blade on the machine that cuts
the plastic sheets, and this blade must be cleaned periodically during the
production process. Since the process must be stopped to clean off the
blade, that this operation is more in the nature of servicing or
maintenance than normal production; on the other hand, since it must be
performed frequently during production, it is arguable also part of the
production process. Because the requirements of the Lockout/Tagout standard
and Subpart O dovetail, protection must be provided regardless of whether
the above operation is considered to be production or servicing. If it is
considered by the employer to be production, the employee must be fully
protected from the dangers of contacting the blade or other harmful machine
parts; the cleaning must be done with special tools and procedures to
provide the necessary protection. However, if it is considered to be
servicing, outside of production, and the employee is exposed to a point of
operation or an associated danger zone, the provisions of the
Lockout/Tagout standard would apply.
To review OSHA regulation 1910.147 and the related Seton products, go to:
