Lockout / Tagout: One of the Top 10 Most Frequently Cited Standards

Lockout/Tagout has occupied a nearly permanent position on the Top 10 Most Frequently Cited Standards by OSHA since the 2015 modification to the injury reporting requirements to report amputations, loss of an eye, or in-patient hospitalization to OSHA within twenty-four hours. Compliance with this standard and its requirements is evaluated in every General Industry OSHA inspection, and local emphasis programs have specifically referenced this standard in the inspection requirements.

Why is this standard so difficult? Often there is a basic misunderstanding of what OSHA means by the term Servicing and Maintenance. OSHA’s definition of Servicing and/or maintenance includes;  Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.  

In some cases, the advancement of machine technology to include powered set up modes becomes a stumbling block.  Tasks that would normally be considered routine to production become lockout tasks if anomalous conditions are found, or maintenance teams did not fully understand what is required for performing troubleshooting. Even employers with robust lockout programs and well-trained personnel can still struggle with some of the requirements of the standard.

One of the most frequently overlooked elements of the standard is the requirement to perform periodic inspections as described in 1910.147(c)(6)(i) The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure the procedure and the requirements of this standard are being followed. Some employers have interpreted this requirement as annual classroom training, but this is not the case.

This inspection must be performed annually within one calendar year of the date of the last inspection and must be certified by the employer.  This documented certification requirement is detailed in 1910.147(c)(6)(ii): 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 employee(s) included in the inspection, and the person performing the inspection. The person performing the inspection must be an Authorized employee other than one who typically works on the machine or equipment being inspected. 

It is best practice to develop a certification form that addresses each of these elements and identifies any deviations from the established machine specific lockout procedure by the Authorized person(s), such as not locking out in the sequence that is specified, or identifies inadequacies in the lockout procedure itself, such as not identifying all the associated energy sources.  Employers must maintain the certification forms on file as they will be requested by compliance officers if OSHA opens an inspection.

For facilities that have a lot of equipment, there are strategies to make performing the periodic inspections more manageable.  Equipment that is the same or similar, with similar energy sources and means of isolation ca ben grouped in the machine specific lockout procedures.  Assessments of authorized personnel may be performed as a group, and the inspections spread out so that a few are done at a time rather than attempting to evaluate everything at the same time. 

Maintenance personnel are expected to have enhanced knowledge of machinery and machine systems, so it would be impractical to perform a periodic inspection for maintenance personnel on each asset within a facility.  It is recommended to perform group assessments with maintenance personnel on various machines with each group inspected on a different set of equipment. Prior to performing maintenance on a piece of equipment after the periodic inspection was performed, maintenance personnel who were not included in the inspection must have the opportunity to review the inspection results from that piece of equipment. 

Minor Servicing

Minor Servicing has the dubious distinction of being another area that tends to cause heartburn to even the most diligent employer.  The Minor Servicing exception allows certain tasks to be performed during normal production provided they are routine, repetitive, integral to the production process, and the employees are effectively protected through machine guarding methods.  The key in this case is that the machine must be performing its intended function for the exception to apply, rather than being prepared to perform that function.  As a best practice, employers should evaluate the tasks that may qualify for this exception to determine if the task can be performed under machine guarding protection, or if lockout is required. 

To evaluate potential minor servicing tasks, involve the operators of the machine as they are the most familiar with the operations and will provide knowledge that is critical to the accuracy of the assessment.  It is also recommended to document findings to demonstrate that the task is consistent with the requirements of the exception.  To perform the evaluation, use the following criteria. 

1. Verify the task occurs during production while the machine is performing its intended function and not during set up or change over which are included in the definition of Servicing and Maintenance and therefore require lockout. For the employer’s purposes, the intended function means that stock is being fed into the machine and product is coming out.
2. The task is routine, occurring as a regular feature of the production process.  It is also repetitive, meaning that the employee will perform it multiple times per shift, and it is an essential (integral) part of the production process. An example of this is blowing chips or scrap away from the point of operation throughout the shift.
3. The final component is what is referred to as effective alternative protection in the standard. This refers to machine guarding methodologies such as interlocks, light curtains, area scanners, or other devices that ensure the machine cannot start or be cycled until the operator has finished the task. As a best practice, redundant, monitored, fail safe (control reliable) systems should be used, or the employer can follow the manufacturer-recommended test procedures for the protective devices that are used.

Testing, Positioning, and Troubleshooting

Employers must consider activities that require equipment to be energized for testing, positioning, or troubleshooting. OSHA acknowledges that there are situations where machines will be energized to perform testing or positioning and includes specific requirements for doing so under 1910.147(f)(1).  To comply with elements of (f)(1), the machine or equipment must be locked out prior to re-energizing to performing the testing or positioning tasks.  This requirement, regarding troubleshooting for maintenance associates, has resulted in spirited debate in some cases with regard to when the machine should be locked out before re-energizing for observation purposes.

It should be noted that when the employee performing the troubleshooting task cannot be located at a safe distance, effective alternative protection via guarding or other procedures must be implemented. Employees are permitted to observe, but not access, a hazard area during troubleshooting until the machine has been locked out.  Employers may be able to standardize protective methods and standard operating procedures for troubleshooting depending upon the tasks taking place in the work environment.

If you have concerns about opportunities within your lockout program it is suggested to work with competent safety professionals and engage qualified outside counsel for ongoing compliance assistance.

Tags: Frequently Cited Standards, Lockout / Tagout, OSHA, OSHA Standards