Search

3 Lockout/Tagout Exclusions You Can Use

Posted on 3/13/2017 by Lee Ann Coniglione

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

Unplug electrical equipment lockout tagoutIn 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 tap work on pressurized pipelineHot 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:
  • 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

29 CFR 1910.147(a)(2)(iii)(B)
 

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.
 

New! Employee Lockout/Tagout Training Online!

OSHA lockout tagout trainingBe 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.  

Tags: lockout, osha, safety, tagout

Find a Post

Compliance Archives

Lion - Quotes

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective.

John Gratacos

Logistics Manager

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

Download Our Latest Whitepaper

Find out what makes DOT hazmat training mandatory for employees who sign the hazardous waste manifest, a “dually regulated” document for tracking shipments.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.