One of the most abused practices involving LOTO is the “myth” that LOTO does not apply when the “energy source” is “under the control of and within line-of-sight of the person performing the activity.” As OSHA points out in this 2007 LOI, this is not necessarily the case:
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Question #1: OSHA identifies pneumatic energy as one source of hazardous energy. Are compressed gas cylinders that feed downstream systems subject to lockout/tagout (LOTO) requirements during activities where the cylinder valve is under the control of and within line-of-sight of the person operating? Representative activities may include replacing gas cylinders that supply laboratory instruments or changing hoses, torches, and tips on gas welding/cutting systems. Response: Yes, the requirements of 29 CFR 1910.147 apply to gas cylinders. The contents of a compressed gas cylinder represent both pneumatic and, in the case of flammable gases, potential thermal energy. The fact that the cylinder valve is under the control of and within the line-of-sight of the person performing the servicing and/or maintenance does not provide protection equivalent to using proper LOTO procedures and devices and does not exempt the activity from the requirements of the standard. |
So, is OSHA saying that we must apply LOTO practices when changing out compressed gas cylinders???
It sure does sound like they are in their response to this question.
I would agree 100% that IF WE USED the cylinder valve as an ISOLATION DEVICE for work on the equipment associated with the compressed gas. Then we would be doing true MAINTENANCE/SERVICING, and when the compressed gas posed a hazard to our work, and it needed to be LOCKED OUT, we would CLOSE the cylinder valve, LOCK IT OUT, and then bleed off the stored energy (e.g., pressure) to a Zero Energy State (ZES). I even require that the “bleed” be LOCKED OPEN to ensure the pressure cannot re-accumulate during the maintenance/servicing.
NOTE: Some companies may require the cylinder valve to be CLOSED. Then, the hose to the machine is disconnected, and the hose connection is locked out rather than using the cylinder valve as the isolation device.
However, if all I was doing was changing cylinders (i.e., removing an empty and replacing it with a charged cylinder), I would NOT apply LOTO to this task. I do not see the need, and professionally I do not believe this task to be “maintenance/servicing,” but that is merely my professional opinion.