More background on OSHA’s consideration of Control Circuit Devices in lieu of LOTO

OSHA is considering whether to initiate rulemaking to revise its control of hazardous energy standard for general industry. One aim of this RFI is to seek public comment on the modernization of the control of hazardous energy standard without compromising worker safety. OSHA is requesting information from the public on its control of hazardous energy standard to help the agency determine how to best protect employees.  OSHA’s control of hazardous energy (Lockout/Tagout) standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of machines or equipment, or release of stored energy, could harm employees. These hazards exist not only for the employees working directly with the machines or equipment but also for the employees nearby. The Lockout/Tagout standard was developed to address these hazards by establishing minimum performance requirements for the control of hazardous energy.  The Lockout/Tagout standard currently requires that all hazardous energy from power sources and energy stored in the machine itself be controlled using energy isolating devices (EIDs) when an employee is performing servicing or maintenance of a machine or equipment. OSHA’s definition of EIDs excludes push buttons, selector switches, and other control circuit type devices.

Nevertheless, OSHA recognizes that there have been safety advancements to control circuit type devices since OSHA adopted the standard in 1989. Accordingly, OSHA is revisiting the Lockout/Tagout standard to consider whether to allow the use of control circuit type devices instead of EIDs for some tasks or under certain conditions. OSHA seeks information, data, and comments that would help the agency determine under which conditions if any, control circuit type devices could safely be used. OSHA is also considering changes to the Lockout/Tagout standard that would reflect new industry best practices and technological advances for hazardous energy control in the robotics industry. OSHA invites information, data, and comments on these and any other issues or concerns that regulated employers, affected employees, and other interested parties may have regarding the existing Lockout/Tagout standard.

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