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If the work activity is simply a minor adjustment or tool change, is full compliance with the provisions of MIOSHA PART 85., Control Of Hazardous Energy Sources Required? The answer is that it depends!

Part 85., commonly referred to as the Lockout-Tagout standard, contains an exception for minor tool adjustments and changes. The exception states that the minor tool adjustment or change or minor serving activity must take place during normal productions operation and must be routine, repetitive, and integral to the use of the equipment for production. If the work activity meets both conditions, then an employer may use alternative measures in lieu of full compliance with the lockout-tagout standard.

Three-Part Test:

To determine whether the exception applies, employers must apply a three-part test.

  1. Is the task a minor tool change or adjustment or minor servicing activity?

  2. Is the task:

    The activity must be a regular course of procedure and in accordance with established

    The activity must be repeated as part of the production process or cycle.

    The activity must be inherent to the production process.

  3. Is the task performed using effective, alternative, protective measures?
The exception is intended to sustain the machine within the acceptable performance range and output quality. It is part and product oriented rather than repair oriented.

If the answers to all three of the questions above are "yes," then the exception applies and the employer may use alternative measures in lieu of full compliance with the lockout-tagout standard.

Assessing the Risk:

The first step in determining acceptable alternative measures is to conduct a risk assessment of the process. There are a variety of risk assessment models that can be used to help with this process.

Review tasks:
In general, risk assessment begins with a review of all tasks and activities to determine those that may be considered minor tool changes, adjustment, and minor serving activities.

Identify Hazards:
Hazards, such as mechanical, electrical, thermal, pneumatic, hydraulic, radiation, residual or stored energy, motion, fuels, and human factors, associated with each task shall be considered. There may also be associated hazards for a particular task not related to hazardous energy release which may also need to be reviewed.

Assess Potential Consequences:
The severity of injuries to all persons that could be harmed by the hazards must be considered. The most severe injury that can reasonably be expected to result from the exposure must be used to determine the protective requirements.

Assess Potential Exposure to the Hazards:
Consider the potential exposure of all persons to the hazards identified. This assessment shall consider the nature, duration, and frequency of exposure to the hazards.

Assess Probability of Occurrence:
To thoroughly assess the probability, there are a number of areas that must be reviewed. Consider the safeguards, safety devices, and safety systems either in use or that will be used. Check the past reliability and potential for failure, operational or maintenance demands of the task, and the likelihood of defeating the safeguards. In addition, review the accident history relating to the task, activity, machine, equipment, and process. The training proficiency, and competence of all persons performing the tasks must be con-sidered. Finally, consider the overall conditions of the work environment.

Evaluate Risk:
Use the information gathered from the above identification and assessment activities to evaluate each identified hazard and task. From the review, determine the level of risk.

Alternative Measures

Once the level of risk has been determined, it is possible to explore whether there are adequate alternative measures available. Alternative measures include all of the following, and employers are expected to select the highest level of feasible control(s).

  • Eliminate the hazards through design.
  • Use full lockout.
  • Use engineered safeguards and techniques such as: area scanners, guards, light curtains, pressure mats, presence sensing devices, or stop devices under exclusive control of the operator.
  • Use warning and alerting devices to include audible, visual devices, or barricades.
  • Use administrative controls such as: work procedures, practices, and training.
  • Use personal protective equipment as appropriate to the hazard.
In many cases, application of any single control measure is not adequate to provide an effective level of protection for employees. In these cases, it is necessary to use a combination of measures.

Appropriate Implementation

The General Industry Safety Division is seeing an increase in the number of employers who have taken the time to thoroughly evaluate the risk of a minor tool adjustment or change or minor serving activity, and are implementing appropriate alternative protective measures.

Some of the examples safety officers have seen involve combinations of procedures requiring a number of steps to restart a machine, redundant interlocks, reduction of machine power to a level where it will not cycle, and taking steps to prevent motion through blocking.

Each circumstance where alternative measures are used is evaluated by safety officers to determine whether the work activity meets the parameters of the exception in the standard, whether the alternative measures provide adequate protection, whether employees are properly trained in the alternative measures, when the measure may be used, when full lockout is required, and whether the employer is providing adequate monitoring to ensure compliance by staff performing the work.

Remember that the ultimate goal, whether using lockout or alternative measures, is to take the steps necessary to ensure that employees are safe during the work activity.

Credit for this article is given to Martha Yoder, Chief, General Industry Division, "MIOSHA News."

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