Can 1910.147(c)(4)(i) be applied to compressed air?

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”)

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.

So if the ONLY source of energy to the machine is compressed air (or any gas for that matter), AND we have a dump valve (as shown below) as our means to isolate the compressed air, would we meet the eight (8) criteria above?  As shown below, we can use a “dump valve” to isolate air because the valve isolates the air, bleeds the air off to a ZES, and ensures that if the isolation valve leaks, the hazardous energy.