Many folks will focus on ONLY three (3) criteria for applying this “exception” to OSHA LOTO standard 1910.147. And these (3) criteria are just opening the gates to LOTO Hell. Far too often we find the “exception” has become the rule and LOTO has become the exception. So what are the FIVE (5) criteria we need to meet to SAFELY apply this “exception”:
Note: Exception to paragraph (a)(2)(ii):
Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if 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 (See subpart O of this part).
As the standard states, the FIRST THREE (3) criteria are:
- Routine
- Repetitive
- Integral
But far too many miss two (2) additional criteria:
- the task is part of NORMAL Operations
- the task requires NO Disassembly (tool changes are NOT considered disassembly)
So now we are up to five (5) criteria that must be met to apply this exception SAFELY.
Source: LOTO CPL (https://www.osha.gov/sites/default/files/enforcement/directives/CPL_02-00-147.pdf)
SAFTENG Members can read my 19 post on this topic in the member’s area.
- OSHRC decision on Minor Servicing using an Interlock and Machine Specific Procedures
- Do you understand the requirements to utilize the minor servicing exemption in OSHA 1910.147?
- Evaluating the application of and the controls associated with “minor servicing”
- Does a manufacturer’s maintenance instruction over-ride OSHA’s “minor servicing” exception?
- OSHRC decision on “minor servicing” and “safety blocks” in lieu of LOTO
- Lockout is the RULE, “minor servicing” is the exception
- MIOSHA Guidance: Minor Tool Changes and Adjustments, and Other Minor Servicing Activities
- Minor Servicing Alternative Safety Measures
- Is LOTO a fair barometer to measure management commitment to worker safety?
- I say this every year, and I get told I am wrong… (LOTO)
- In a mature LOTO program, “SCOPE of WORK” matters
- Viewing OSHA’s Control of Hazardous Energy through the lens of an SMS
- More background on OSHA’s consideration of Control Circuit Devices in lieu of LOTO
- Are you ready for a new LOTO standard, one that would allow interlocks to be used in lieu of LOTO?
- 67 incidents & 1 update (12/22/15)
- OSHA grants VARIANCE to Lockout (1910.147(d)(4)(i)
- 49 incidents & 1 update (3/29/14)
- FALSE Sense of Safety…using interlocks in Lieu of LOTO!!!
- 37 incidents & 1 update (3/17/14)