OSHA answers the common questions regarding LOTO Feasibility and Alternative Methods

Background: You stated that your client must perform service and maintenance tasks that will require power in certain circumstances. Some of the tasks qualify for the minor servicing exception to 29 CFR §1910.147 standard. However, there are other tasks that are considered service and maintenance, but still require power. An example is setting up a machine for change over to a new product run. You recognize that such tasks are not normal production, and the requirements of 29 CFR §1910.147 apply. However, the task of set-up or change-over requires control functions for inch, jog, etc. and cannot be done when the primary energy source is isolated and locked.

FYI… OSHA does NOT recognize “Alternative Methods” as defined in ANSI B11.0-2020 and ANSI Z244.1-2016.

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