We have a machine and this machine has a couple of tasks that have been deemed “minor servicing”. As we walk by we see a worker in the machine and no LOTO in place so of course we stop and ask about the situation. We are told the task being done, “XXXXXXXX”, is indeed a “minor servicing” task approved by the safety department. We continue on our way. About 45 minutes later we are on our way back and yet again come upon the same worker in the same machine zone as if he never ended his task from earlier. So inquisitive minds want to know… is he doing the same task as when we walked by 45 minutes earlier? He, in fact, was doing the same task and this task “on average, takes over an hour”. So I ask you, a task that takes over an hour, is it “minor” in your mental image of what OSHA’s minor servicing exception is intended to allow? There is more to this situation, but ultimately the exception was reversed based on the following:
(NOTE for non-members – the exception was reversed based on more facts than time)
So for those of us who live LOTO on a daily basis, we have come to see the “minor exception” become the norm and LOTO becomes the exception! This is human nature. So what does OSHA says about their “minor servicing exception:
The Lockout/Tagout standard contains specific criteria that MUST be met for the “minor servicing exception” to apply. Minor tool changes and adjustments, and other minor servicing activities that take place during NORMAL PRODUCTION OPERATIONS (no disassembly), are not covered by the standard WHEN 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.
OSHA lists five (5) specific criteria that MUST be used to determine if the minor servicing exception would apply to a particular activity. This information is in their 2008 LOTO CPL and I have listed them here in summary:
- The activity MUST be conducted during NORMAL PRODUCTION OPERATIONS (i.e., while the machine or equipment is actually performing its intended production function).
- The activity does NOT involve any “dis-assembly” of parts or equipment
- The activity is Routine: The activity must be a regular course of procedure done on a daily/shift basis and be in accordance with established practices.
- The activity is Repetitive: The activity must be regularly repeated during each shift as part of the production process.
- The activity is Integral: The activity must be essential to the production process.
PLEASE NOTE that the quantifying of the words “routine” and repetitive” is my way of trying to narrow the option for this EXCEPTION. To my knowledge, OSHA has never quantified these terms. I should also point out that OSHA sort of qualifies “disassembly” in the CPL by using the phrase “EXTENSIVE DISASSEMBLY”.
The worker we observed was doing a task that met ALL five (5) of the criteria for the “minor servicing” exception. But here is the catch to what we discovered… the machine did not need to be energized during the task and the machine manufacturer’s manual states the machine is to be “OFF” to do the task. Yes, the door/guard the worker was performing the task behind was “interlocked” and it was a CAT 4 Level interlock, but that interlock was engineered into place by the manufacturer for the operator(s) to perform other production and quality-related tasks that did require the machine to be “ON” in order to perform the tasks properly.
So the question was asked as to why this was considered “minor servicing” and being done with the machine “ON” when in fact the manufacturer of the machine states it is to be “OFF”. We also found that the LOTO for this machine was a single electrical disconnect and an air isolation dump valve and both energy isolation devices are right at the machine and could be activated with a lock applied in less than 2 minutes. So again, why would this task be managed as a minor servicing task rather than a LOTO task?
The facility came clean and they admitted they knew this task was a LOTO task and that the “minor servicing” exception had become the rule and LOTO had become the “exception” because it was just easier to let employees use the interlock than it was to put them in the LOTO program as Authorized Employees.
Moral of the story…
Even when the task meets ALL of OSHA’s criteria for being a “minor servicing” task, if the task can be done under the protection of LOTO then we do LOTO. The task not only has to meet all of OSHA’s criteria for “minor servicing” we also MUST look at the impact locking out would have on the production process. This is the FULL INTENT of why OSHA included the “minor servicing” exception.
For example…
I have a packaging machine that groups and packages 6,000 items an hour. In that 1-hour window, I could have up to 30 items to be in the wrong position per hour. So the worker stops the machine. He/She spends 2 minutes locking out the machine, fixes the item in the wrong position, closes the machine, removes his/her LOTO devices, and restarts the machine from the control panel.
Two minutes may not seem like a large burden to overcome, but when these 2-minute tasks happen 30 times per hour, how long do you think the business would remain in operation?!?!? So we can look to minimize the lockout procedure to shave off 1-minute by providing dedicated locks and moving both energy isolation devices to the same location, but that is not going to keep us in business. So OSHA’s minor servicing task is a solution for this item in the wrong position. We can use a SAFE alternative to the employee spending the 1-2 minutes locking out the machine 30 times per hour. In most cases, this SAFE alternative is a properly designed, installed and maintained interlock. So the worker can SAFELY open the door/guard to the machine, correct the item’s position, close the door and restart the machine in about 5-10 seconds. This is the intent of the “minor servicing” exception. it is called an “EXCEPTION” for a reason and NEVER should it become the norm. In fact, in my facilities (and now my clients’ facilities where I am involved in LOTO matters), management has to move a mountain to get a minor servicing exception past me. I have a very formal process, with multiple approvals from all parties (supervisor, dept. manager, safety, maintenance, and plant manager). Employees are told in LOTO training to LOCK IT OUT if there is NOT a documented “minor servicing” procedure in place and they have been TRAINED in the said procedure.
Yes, I make it difficult on PURPOSE. We (safety professionals) should all live by the motto:
If in Doubt – Lock it Out!
If there is not a label on the door/guard/cover stating:
- the APPROVED “minor servicing” tasks that can be done behind the door/guard/cover AND
- the APPROVED Alternative Protection
then that employee MUST utilize LOTO to perform said task. Getting caught inside a machine/equipment without the protection of LOTO doing a task that is NOT on the APPROVED list of tasks is the same as NOT locking out! Using the “exception” is SERIOUS business and if we choose to bypass one of the most fundamental safety practices over the past 35 years we better be DAMN SURE we are doing it right!