Luckily, these kinds of encounters are dwindling, but even mentioning this in 2019 says a lot for the “State of Safety” in the USA. Have you ever encountered a management group where you hoped Dr. Suess would re-write the OSHA LOTO Std? I mean, they hire us to explain and assist in implementing the basic safety programs – LOTO being one of the top three CORE PROGRAMS (IMPO!). So I am attempting to explain how LOTO will apply to their workplace and one of the team ask me to show them in the standard where it says that when an energy isolation requires more than a single lock, or tag, that the LOTO must have a written “machine/equipment specific” procedure. Unfortunately, OSHA does not write its standards such that they come out and state this verbatim. Still, as I said in my article covering the LOTO Exception for written procedures, it is rare when a written isolation plan is NOT required to meet the OSHA minimums. So, where in the standard does OSHA require written procedures?
(emphasis by me)
1910.147(a)(3)(i) This section REQUIRES employers to establish a program and UTILIZE PROCEDURES for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees.
Which leads us to:
1910.147(c)(4) Energy control procedure.
1910.147(c)(4)(i) 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.
Note: Exception: The employer need NOT document the REQUIRED PROCEDURE for a particular machine or equipment when ALL 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;
(5) a single lockout device will achieve a locked-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.
1910.147(c)(4)(ii) 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:
So, although Dr. Suess did not write 1910.147, when one reads it and understands its APPLICATION, it is quite apparent that machine/equipment-specific procedures are REQUIRED unless the energy isolation meets ALL EIGHT (8) of the requirements in the exception. Trust me!
Source:
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147
https://www.osha.gov/sites/default/files/enforcement/directives/CPL_02-00-147.pdf