As we have discussed, the “note and exception” that goes with 1910.147(c)(4)(i) is what I call “simple lockout”; however, I have always stated it was intended for simple electrical lockouts, seeing how one of the hurdles to using the exception was that there could be no “stored energy.” So, when we look at the eight (8) criteria that must be met in order to declare the lockout is a “simple lockout,” it reads that the source of energy is electrical.
But in today’s workplace, we have “dump valves” that many workplaces are installing to make “air” a “simple lockout,” and when we compare the uses of these devices for isolating air, we can now declare air as a “simple lockout.” Let’s break this down so it makes sense…
Here are the eight (8) criteria to be met in order to claim a “machine/equipment-specific procedure” is not required (e.g., it is a “simple lockout”)
