Lockout / Tagout - Ohio Bureau of Workers' Compensation

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contradict the guidance provided in OSHA's Instruction STD 1-7.3 which clearly states that group meetings with all authorized employees constitutes compliance with the standard. If the standard and the instructional guidance are to be consistent, then group meetings between an inspector and all authorized employees comply with 1910.147(c)(6)(i), provided the inspection includes a review of the responsibilities of each authorized employee and a demonstration of the energy control procedures. Question: Does 1910.147(c)(6)(i) require that all authorized employee demonstrate energy control procedures during the periodic inspection? As stated above, the lockout/tagout standard requires that the periodic inspection include a "review" of the employee's responsibilities under the energy control procedures. Generally, an inspector who observes deficiencies in authorized employees understanding of the lockout/tagout program during the period inspection will counsel the employees on the correct energy control procedures. If several employees are performing maintenance on a particular machine, the inspector may request that one employee demonstrate the energy control procedures utilized on that machine, while the other employees observe. The inspector will then review the responsibilities of each authorized employee under the energy control procedure being inspected. Likewise, the inspector may assemble several authorized employees and request that one employee demonstrate the lockout procedures while the others observe. In each case, all employees are participating in a lockout demonstration and receive feedback on the correct procedures. In the OSHA Memorandum, dated March 6, 1995, Mr. Wiehrdt indicates that such a group meeting of employees will not comply with 1910.147(c)(6)(i), since each authorized employee in the group does not individually demonstrate the energy control procedures for the inspector. Our readings of the regulation and the interpretive guidance provided by the National office indicates that OSHA does not require that every employee demonstrate lockout/tagout procedures during the periodic inspection. Based on our questions, we request that your office provide additional interpretation of the periodic inspection requirements contained in the Lockout/Tagout Standard. Attached to this letter is the Memorandum dated March 6, 1995 from William Wiehrdt to Mel Lischefski. If you have any questions regarding our request, please feel free to call. Your cooperation is appreciated. Very truly yours, KRUKOWSKI & COSTELLO, S.C. Stuart Charlson 7-13
OSHA Standards Interpretation and Compliance Letters 01/05/1998 - Interpretation/variance with the energy isolation device requirements. • Record Type: Interpretation • Standard Number: 1910.147;1910.147(b);1910.147(c)(1) • Subject: Interpretation/variance with the energy isolation device requirements. • Information Date:01/05/1998 January 5, 1998 Mr. Richard J. Hackman The Proctor & Gamble Company Ivorydale Technical Center 5299 Spring Grove Avenue Cincinnati, Ohio 45217-1087 Dear Mr. Hackman: This is in response to your November 8, 1996 letter and enclosure, requesting interpretation/variance with the energy isolation device requirements of 29 CFR 1910.147. Please accept our apology for the delay in responding. In your letter you described a safety disconnect system ("system") which protects directly wired load circuits to (functionally interconnected) process machines from being energized by an electrical source. Also, you stated that this system is intended for use with process machines where it is impractical to provide manually-operated disconnects at every point of access. Further, you disclosed that direct power interruption on the large drives of these process machines is infeasible because the disconnects require a significant effort to operate, are difficult to position in the (production) line layout, and are not constructed for frequent use. As noted in your letter, the safety disconnect system includes the following four basic, component groups: a power contractor, a control power transformer and fuses, voltage sensing relays, and a safety lockout switch with verification light. An optional component is used to establish a required neutral point for the voltage sensing relays, if the power being monitored is derived from an ungrounded system. The following system safety features are noted relative to the results of the failure analysis included in your letter: • The system measures and ensures no motive force to the drive system. • The system provides fail-safe verification, that is, defaults to the safe position. 7-14
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Lockout / Tagout Class Agenda and O
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Lockout / Tagout Course Objectives
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Activity Plan q Activity Other peop
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The following accidents, taken from
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V. Identify Different Personnel u A
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XI. Miscellaneous Items in Your Pro
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OSHA Regulations (Standards - 29 CF
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(a)(3) "Purpose." (a)(3)(i) This se
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(c)(2) "Lockout/tagout." (c)(2)(i)
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(c)(5)(ii) Lockout devices and tago
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(c)(7)(i)(A) Each authorized employ
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(d)(2) (d)(3) (d)(4) "Machine or eq
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(e)(3)(ii) Making all reasonable ef
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OSHA Regulations (Standards - 29 CF
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(7) Ensure that the equipment is di
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III. Definitions Authorized employe
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D. Lockout Device Application. 1. A
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3. Ensure that our employees unders
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APPENDIX A TAGOUT PROCEDURES A. Whe
Page 55 and 56: DATE: _____/_____/_____ APPENDIX C
Page 57 and 58: APPENDIX E ENERGY SOURCE EVALUATION
Page 59 and 60: 2 of 3 APPENDIX F 5. A. Apply locks
Page 61 and 62: APPENDIX G-1 “Authorized” Emplo
Page 63 and 64: APPENDIX G-3 “Other” Employee T
Page 65 and 66: HAZARDOUS ENERGY CONTROL PROCEDURES
Page 67 and 68: Appendix I Audit Checklist Review t
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Page 74 and 75: Employer Responsibilities (continue
Page 76 and 77: Preventing Shock • Safety Plannin
Page 79 and 80: OSHA Regulations (Standards - 29 CF
Page 81 and 82: (c)(2) (c)(3) (c)(4) Communications
Page 83 and 84: (b)(3)(ii) The skills and technique
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Page 91 and 92: (c)(3)(iii)(B)(2) The equipment is
Page 94 and 95: OSHA Standards Interpretation and C
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Page 98 and 99: guards and/or devices assure employ
Page 108 and 109: • Verification is provided by a s
Page 110 and 111: Question: Reply: Would interlocking
Page 113 and 114: The following document is reproduce
Page 116 and 117: WHY THIS LOCKOUT IMPLEMENTATION KIT
Page 118 and 119: LOCKOUT STANDARD CHRONOLOGY Februar
Page 120 and 121: 6. Industry sectors, such as constr
Page 122 and 123: f. Each element of this program wil
Page 124 and 125: h. Locks shall be attached to each
Page 126 and 127: Training records such as attendance
Page 128 and 129: (b) (c) (d) (e) (f) Machinery equip
Page 130 and 131: (iv) Prior to lockout device remova
Page 132 and 133: APPENDIX A - SAMPLE FORMS Form No.
Page 134 and 135: Form No.2 WRITTEN PROCEDURE ELEMENT
Page 136 and 137: Are alternate energy control method
Page 138 and 139: Is procedure adequate? ____________
Page 140 and 141: Is job procedure for removal being
Page 142 and 143: 11. Have attempts been made to cont
Page 144 and 145: Document No- 1 PLANNING FOR TRAININ
Page 146 and 147: 8. The retraining must reestablish
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Page 152: One Hour Safety Presentation The ma
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Elements of a Lockout/Tagout Progra
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Identify Different Personnel u Auth
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List & Identify all Sources Of Ener
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Procedures For Each Piece Of u Writ
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Training Affected & Other Employees
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Develop Procedures On How You Will
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Miscellaneous Items in Your Program
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Other Things To Consider u When do
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Elements of a Lockout/Tagout Progra
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Identify Different Personnel u Auth
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List & Identify all Sources Of Ener
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Procedures For Each Piece Of Equipm
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Training Affected & Other Employees
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Develop Procedures on how you will
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Miscellaneous Items in Your Program
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Other Things To Consider u When do
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If an energy isolating device is ca
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Student Handouts
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Training Of Authorized Employees. u
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Shift & Personnel Changes u How to
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Resources Available from the Divisi
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Saving You Time and Research Reques
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The CDC is always a good resource f
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http://www.fmcsa.dot.gov/safetyprog
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Lockout / Tagout - Ohio Bureau of Workers' Compensation

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