Lockout / Tagout

1. Lockout /Tagout 1910.147 The Control of Hazardous Energy

2. 1910.147(a)(1) Scope • 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.

3. 1910(a)(1)(ii) Exemptions • Construction, agriculture and maritime employment; • Electrical Utilities; • Exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations, which is covered by Subpart S of this part; and • Oil and gas well drilling and servicing

4. 1910.147(a)(3) Purpose • Establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices • Prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees

5. 1910.147(c) General Requirements • The employer shall establish a program consisting of: • Energy control procedures, • Employee training and, • Periodic inspections • To ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

6. 1910.147(c)(4) General Requirements • "Energy control procedure.” • Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

7. Note: "Exception:" The employer need not document the required procedure for a particular machine or equipment, when all (8) of the following elements exist: • [1] The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees • [2] the machine or equipment has a single energy source which can be readily identified and isolated • [3] the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment • [4] the machine or equipment is isolated from that energy source and locked out during servicing or maintenance

8. Note: "Exception:" (continued) when all of the following elements exist: • [5] a single lockout device will achieve a lock-out condition • [6] the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance • [7] the servicing or maintenance does not create hazards for other employees; and • [8] the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance

9. 1910.147(c)(4) General Requirements - Energy Control Procedure • The procedures shall clearly and specifically outline the: • Scope, • Purpose, • Authorization, • Rules, and • Techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following:

10. Energy Control Procedures • A specific statement of the intended use of the procedure; • Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;

11. Energy Control Procedure • Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and • Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures

12. Standard Interpretations Applicability of OSHA's LOTO standards; isolation and verification procedures • As you seem to recognize, there are two standards that are most directly applicable to the circumstance described in your letter: 29 CFR 1910.147, The control of hazardous energy (lockout/tagout), and 29 CFR 1910.333, Selection and use of safe work practices. • Section 1910.147 covers the servicing and maintenance of machines and equipment in which uncontrolled hazardous energy could cause injury to employees. • Section 1910.333(b) provides procedures to protect employees who are working on or near exposed de-energized electric parts.

13. Standard Interpretations Applicability of OSHA's LOTO standards; isolation and verification procedures • Both standards mandate the use of locks and/or tags to control potentially hazardous energy.1 Footnote(1) Lockout and tagging procedures that comply with paragraphs (c) through (f) of §1910.147 constitute compliance with §1910.333(b)(2), as long as the procedures address the electrical safety hazards covered by Subpart S and incorporate the requirements of §1910.333(b)(2)(iii)(D) and (iv)(B).

14. Standard Interpretations 11/16/2000 - Applicability of OSHA's LOTO standards; isolation and verification procedures • Whether the authorized or qualified employee verifies effective isolation and de-energization depends upon the energy source. • For example, an electric disconnect switch may control a mechanical or an electrical energy hazard, or both, depending on the electrical system design and the nature of the work tasks involved.

15. Standard Interpretations Applicability of OSHA's LOTO standards; isolation and verification procedures • With respect to employees working on or near de-energized electrical utilization systems (covered by Subpart S, Electrical, standards), both the authorized employee and the qualified employee are permitted to verify that electrical equipment has been de-energized. • However, the authorized employee would need to meet and be trained on all qualified employee requirements in 1910.331 through 1910.335 and 1910.399.

16. Standard Interpretations 11/16/2000 - Applicability of OSHA's LOTO standards; isolation and verification procedures • The verification of isolation for mechanical hazardous energy, on the other hand, is addressed by paragraph 1910.147(d)(6). • The authorized employee(s) must, prior to the start of work, verify that the previous steps of the energy control procedure have effectively isolated the machine or equipment.

17. Standard Interpretations Applicability of OSHA's LOTO standards; isolation and verification procedures • These steps must include verification that the machine or equipment has been turned off properly; • That all energy isolating devices were identified, located, and operated; • That the lockout or tagout devices (or application of a lock and tag for electrical control purposes) have been attached to energy isolating devices; and • That stored energy has been released, discharged, and rendered safe.

18. S A M P L E P R O C E D U R E

19. 1910.147(c)(6) Periodic Inspection • The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed

20. 1910.147(c)(6) Periodic Inspection • (A) The periodic inspection shall be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected • (B) The periodic inspection shall be conducted to correct any deviations or inadequacies identified

21. 1910.147(c)(6)(i)(C) Periodic Inspection • The periodic inspection shall include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected

22. 1910.147 (c)(6)(ii) Periodic Inspection • The employer shall certify that the periodic inspections have been performed. • The certification shall identify: • The machine or equipment on which the energy control procedure was being utilized, • The date of the inspection, • The employees included in the inspection, and • The person performing the inspection.

23. Standard Interpretations Confirmation on lockout/tagout, specifically with the standard covering periodic inspections • These inspections shall at least provide for a demonstration of the procedures and may be implemented through random audits and planned visual observations.

24. Standard Interpretations Confirmation on lockout/tagout, specifically with the standard covering periodic inspections • These inspections are intended to ensure that the energy control procedures are being properly implemented and to provide an essential check on the continued utilization of the procedures.