As human nature goes, we know if we give an inch, some will take a mile. This belief could not be more real than in Lockout/Tagout and the “Minor Servicing” exception. The “rule” is to LOCK IT OUT, and the “minor servicing” exception is just that, an exception to the rule. OSHA has set the bar pretty high for what we can claim as “minor servicing,” and this article looks to dispel the myths behind this abused “exception”.
First, let’s point out what should be obvious to most but not to many! The exception is called the “minor SERVICING” exception and NOT the “minor MAINTENANCE” exception. This is huge, as OSHA NEVER intended this exception to apply to actual maintenance activities, which they define as:
Activities that are necessary to prepare or maintain a machine or piece of equipment are not considered utilization and are considered servicing and/or maintenance activities. Some of these workplace activities may include constructing, installing, setting up, modifying, maintaining, lubricating, cleaning, un-jamming, making minor adjustments, and tool changes.
OSHA makes this clear by stating that the “minor servicing” activities are part of the “normal production operations” in the note associated with 1910.147(a)(2)(ii)(B).
1910.147(a)(2)(ii)(B) An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.
Note: Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).
OSHA does define “normal production operations” in their 2008 LOTO CPL:
The utilization of a machine or equipment to perform its intended production function. The physical act or process of removing or releasing the isolation (e.g., opening electrical disconnects or valves), during the start-up process, as well as machine or equipment re-energization and/or startup, is considered a normal production operation.
Second, OSHA sets out three (3) other hurdles (on top of the first one… part of “normal production operations”) we must clear to utilize the “minor servicing” exception. The task(s) MUST BE 1) routine, 2) repetitive, and 3) integral to the use of machines or equipment for production. Now OSHA does not quantify these terms, but they do define them…
Routine: The activity must be performed as part of a regular and prescribed course of procedure and be performed in accordance with established practices.
Repetitive: The activity must be repeated regularly as part of the production process or cycle.
Integral: The activity must be inherent to the production process.
So now we have defined the four (4) hurdles a facility must cross BEFORE claiming the “minor servicing” task.
- Part of the “normal production operations”
- Routine: The activity must be performed as part of a regular and prescribed course of procedure and be performed in accordance with established practices.
- Repetitive: The activity must be repeated regularly as part of the production process or cycle.
- Integral: The activity must be inherent to the production process. Lastly, OSHA provides some sound guidance in their 2008 CPL when applying this “exception” to LOTO.
OSHA even defines the term “minor servicing exception”…
Minor Servicing Exception to the Lockout/Tagout Standard. Activities such as lubrication, cleaning, un-jamming, servicing of machines or equipment, and making adjustments or tool changes are covered by the LOTO standard, if employees may be exposed to hazardous energy. However, some activities properly are classified as “servicing and/or maintenance” activities, but they are minor in nature and performed during normal production operations. Operations such as lubricating, draining sumps, servicing filters, making simple adjustments, and inspecting for leaks and/or malfunction are examples of routine servicing and maintenance activities, which often can be accomplished safely with effective production-mode safeguards, such as machine guarding methods consistent with the provisions of 29 CFR §1910, Subpart O. These servicing tasks do not require extensive disassembly of the machinery/equipment.
So minor tool changes and adjustments, and other minor servicing operations, which take place during normal production operations, are NOT covered by this standard if they are routine, repetitive, and integral to the use of machines or equipment for production, AND if work is performed using alternative protective measures which provide effective employee protection. LOTO is not required when EACH AND EVERY one of these four (4) elements exists, and employees may perform minor servicing activities with the machine or equipment energized. However, activities requiring machine or equipment shutoff and disassembly, such as changing a machine tool or cutting blade, usually take place outside of the normal production process and require an energy isolating device (LOTO) in accordance with §1910.147. For example, changing an abrasive grinding wheel takes place outside of the normal production process: the machine is turned off, grinding operations stop, a guard is removed, and the wheel retainer nut is loosened and removed. Therefore, the §1910.147(a)(2)(ii) minor servicing exception does NOT apply to this operation.
PLEASE NOTE: the above example of changing a grinding wheel is taken directly from the 2008 LOTO CPL, and although this is a great example of how this task would be a LOTO task, it overlooks the fact that most abrasive grinders are “cord and plug” equipment which would NOT require LOTO as long as the worker had EXCLUSIVE CONTROL of the plug while changing out the wheel.
Furthermore, replacing machine or equipment components – such as belts, valves, gauges, linkages, support structure, etc. — normally is NOT considered a routine function that can be safely accomplished when a machine or piece of equipment is operating. These types of activities need to be performed in accordance with the requirements of the LOTO standard. In addition, any servicing and/or maintenance activity, which takes place during the machine’s or equipment’s normal production operation, is covered by the LOTO standard if employee exposure to hazardous energy (e.g., employee bypasses a guard; placement of a body part into a machine danger zone) exists. See §§ 1910.147(a)(2)(ii)(A) and (B).
In short, the general rule is that servicing and/or maintenance must be performed under LOTO requirements. However, the LOTO standard is not intended to cover certain minor servicing activities necessary to carry out the production process, provided that all of the criteria detailed in the exception are met. Nonetheless, excluding LOTO does not mean that the employer can avoid providing employee protection even though employees carry out these minor servicing tasks with energized machines or equipment. Rather, to take advantage of the limited exception, an employer must provide effective alternative protection in lieu of LOTO.
SAFTENG members may Click Here for my article on the “Alternative Protection” methods.
SAFTENG members may CLICK HERE (.doc) to download my “Minor Servicing Exception” procedure which I always had as an Appendix to my program.