The OSHA standard 29 CFR 1910.147, Control of Hazardous
Energy (Lockout/Tagout) is a complex standard that most companies need to
comply with. The standard requires
employers to disable equipment to control potentially hazardous energy
sources-such as electricity, pneumatic or hydraulic energy when servicing or
maintaining the equipment. Given the
complexity of this regulation, much can be learned from the OSHA inspection
directive.
On February 11, 2008 OSHA issued a revised compliance
directive CPL 02-00-147, The Control of Hazardous Energy – Enforcement Policy
and Inspection Procedures. This
directive replaces OSHA Instruction, STD 01-05-019 [STD 1-7.3], 29 CFR
1910.147, The Control of Hazardous Energy (Lockout/Tagout) -- Inspection
Procedures and Interpretive Guidance, September 11, 1990. In addition, as part of the revision
process, OSHA has removed and archived interpretations from its public web-site
that no longer reflect current policy and/or are superseded by this revised
OSHA Instruction.
Directives are written to provide OSHA personnel with
guidance on how to interpret and enforce OSHA standards. A Directive is not a
legal rule and does not require employers to implement any practices beyond
those required by OSHA's standards. Directives, however, can be a useful guide
for employers by providing information and guidance not found in the standards
themselves or in other publications on OSHA's website. By consulting a
Directive, employers can determine what OSHA is looking for during an inspection.
The significant changes to the directive include (directive
page number is in brackets following each bulleted item):
- Addition
of Compliance Officer Safety guidelines [2-1];
- Inclusion
of Citation Examples [2-11] and additional guidance regarding Affirmative
Defenses (action by employer to excuse the violation including “Greater
Hazard”, “Impossibility”, and “Unpreventable Employee Misconduct and
Isolated Instance”.) [2-32];
- Incorporation
of compliance assistance flowcharts (the flow charts are to be used for
determining program effectiveness) [3-19 through 3-21];
- Inclusion
of additional guidance on the minor servicing exception [2-16, 3-25], unexpected
energization [3‑2], specific energy control procedures [3-39], and periodic
inspections [3-65];
- Inclusion
of additional information and guidance on Alternative Methods to
Lockout/Tagout (LOTO) [2-15];
- Inclusion
of general reference material for information pertinent to hazardous
energy control, including governmental, industry and national consensus
standards [2-22, 3-8]; and
- Addition
of vehicle repair and maintenance standards and practices, including
relevant Internet links, to assist employers engaged in these activities
with hazardous energy control [3-22].
In addition, OSHA is taking a phased approach on this
revision of this instruction. The
second phase will include the incorporation of existing letters of
interpretation and frequently asked questions.
H&A will utilize this information to ensure our current
OSHA Compliance Assistance Program client’s Lockout/Tagout programs align with
the new information found in the Directive.
If you are not in this program and would like to have us
review your current Lockout/Tagout program, please contact Ken Schmerber at
303.384.9828 extension 107.
