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Lockout / Tagout - Ohio Bureau of Workers' Compensation

Lockout / Tagout - Ohio Bureau of Workers' Compensation

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• Verification is provided by a system which actively confirms zero-energy state to the<br />

drives before the verification light comes on.<br />

• When an individual initiates the lockout sequence by opening the system switch and<br />

placing a lock on it, then the verification light will come on, if the machine is at a<br />

zero-energy state.<br />

• If the light goes out due to bulb failure while an authorized employee is performing<br />

servicing and maintenance on the machine, the system remains safe because the<br />

switch is open and locked out.<br />

• The system is designed such that failure <strong>of</strong> any component in the system will not<br />

result in the light coming on when the machine is in an unsafe mode.<br />

• The system is contained in sealed, protected box.<br />

• The equipment used is certified by a nationally recognized testing laboratory.<br />

• An independent laboratory did a system risk analysis and determined the proposed<br />

system presented the lowest risk to the operator.<br />

Based on the information enclosed in your letter, your "safety disconnect system" has<br />

been evaluated as an inherently fail-safe system which performs the same function as<br />

an energy isolating device identified in paragraph 1910.147(b). When used as an<br />

energy isolating device, this "safety system" must be addressed in the energy control<br />

program required in §1910.147(c)(1).<br />

Of particular concern is other hazardous energy sources which are not isolated by the<br />

safety disconnect system. For example, the machine glue heaters are directly<br />

connected (on the supply side <strong>of</strong> the safety disconnect system) to the hazardous<br />

electrical energy source. Potential employee exposure to glue heater hazardous<br />

electrical and thermal energy during servicing and maintenance <strong>of</strong> machines must be<br />

addressed in the energy control program.<br />

We appreciate your interest in employee safety and health. If we can be <strong>of</strong> further<br />

assistance, please contact the Office <strong>of</strong> Safety Compliance Assistance, Mr. Ronald J.<br />

Davies, telephone (202) 219-8031, extension 110.<br />

Sincerely,<br />

John B. Miles, Jr., Director<br />

Directorate <strong>of</strong> Compliance Programs<br />

7-15

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