In which situations is minor servicing of equipment allowed without requiring a specific energy control procedure? Answered by Tracie Cady, manager, research and development, Labelmaster, Chicago.
Exception from the requirement to have a specific "Energy Control Procedure" is detailed in OSHA's 29 CFR 1910.147 (c) (4) (i) lockout/tagout regulation. It states:
"The employer need not document the required procedure for a particular machine or equipment, when all the following elements exist:
- The machine or equipment has no potential for stored or residual energy or re-accumulation of stored energy after shut down which could endanger employees.
- The machine or equipment has a single energy source which can be readily identified and isolated.
- The isolation and locking out of that energy source will completely de-energize and deactivate the machine or equipment.
- The machine or equipment is isolated from that energy source and locked out during servicing or maintenance.
- A single lockout device will achieve a lockout condition.
- The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance.
- The servicing or maintenance does not create hazards for other employees.
- The employer, in utilizing this exception, has had no accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance."
Note that all of the above criteria must be met for minor servicing to take place without a specific energy control procedure.
It is not always possible to have a documented procedure for every circumstance, as procedures may vary based on the specific task being performed. In these instances, a work permit system may be utilized by having a safety manager perform a hazard analysis prior to the task being performed. The task-specific safe work procedure can then be documented in the work permit.
OSHA currently does not require documented procedures for minor servicing that is routine, repetitive and integral to the production operation. However, minor servicing activities sometimes can prove to be problematic. While not specifically required by OSHA, having written procedures for all equipment and processes where workers can possibly be exposed to hazardous energy is good safety practice.