Last week in Lion News
, we discussed the basic requirements of OSHA’s Lockout/Tagout (LOTO) standard at 29 CFR 1910.147 for machine work, service, and maintenance. If you haven’t read that post yet, check it out now: When Do OSHA Lockout/Tagout Rules Apply at My Site?
Now that the basics are out of the way, let’s talk about specific situations which do not fall under the scope of OSHA’s Lockout/Tagout Standard, and why.
While lockout/tagout does not apply in the following situations, OSHA requires employers and employees to take precautions to safeguard workers' wellbeing. A full understanding of what OSHA does
require in these scenarios is crucial to protect the employees who do some of the most dangerous work at your site. By following the required safety procedures during machine maintenance or service, employees can keep normal operations moving smoothly without unnecessarily risking their safety or health, even when full lockout/tagout procedures are not required.
LOTO Exclusion #1: Plugged-in Equipment
In general, work being performed on equipment that is connected to an electrical source via cord and plug is not subject to LOTO. That being said, OSHA explicitly sets forth a couple of conditions that must be satisfied
in order to capitalize on this exception.
First, unexpected energization or startup of the equipment must be controlled by unplugging the equipment from the energy source (e.g., electrical outlet.) Second, the plug must be under the exclusive control of the person performing the work on the equipment/machinery. 29 CFR 1910.147(a)(2)(iii)(A)
LOTO Exclusion #2: Hot Tap Work on Pressurized Pipelines
Hot tapping or pressure tapping performed on pressurized pipelines involving the transmission and distribution of gas, water, steam, or petroleum products is also excluded from the LOTO standard. For this exclusion to apply, you must meet four requirements:
29 CFR 1910.147(a)(2)(iii)(B)
- Continued service of the material (e.g., gas, water) must be shown to be essential
- Shutdown of the system must be deemed impractical
- The work must be performed according to documented procedures
- Special equipment must be utilized which provides effective employee protection from hazards
LOTO Exclusion #3: Minor Tool Changes and Adjustments
From time to time, employees may need to make minor adjustments during normal production operations. Normal production operations are not subject to OSHA’s Lockout/Tagout Standard unless:
- An employee is required to remove or bypass a guard or other safety device; or
- An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed or where an associated danger zone exists during a machine operating cycle.
If either of the two conditions above is true, then lockout/tagout does apply.
That said, there are times during normal operations when adherence to lockout/tagout rules would disrupt the production process or make required maintenance impossible. In these cases—provided that the work is routine, repetitive, and integral to the use of the equipment—lockout/tagout does not
apply, as long as employees take other safety precautions under OSHA’s machine guarding standard in 29 CFR 1910, Subpart O. 29 CFR 1910.147(a)(ii)
While effective lockout/tagout procedures are absolutely crucial to employee safety, capitalizing on these exclusions can provide needed relief in real-world situations. Knowing when lockout/tagout applies, and when it doesn’t, can help you run a more efficient safety program and prevent severe injuries to your employees.
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Be confident your employees know what it takes to protect themselves and co-workers with effective lockout/tagout procedures. Only $29 per student, the new Lockout/Tagout Online Course
guides employees through the application and removal of lockout/tagout devices. Workers who complete this course will have a stronger understanding of the hazards they face and the requirements they must follow to prevent injuries and keep your site in compliance.