- Record Type: Interpretation
- Standard Number: 1910.147
- Subject: Concerning the
new lockout/tagout standard.
- Information Date:1990
May 1, 1990
Mr. Chuck Mullen, Jr. Corporate Safety
Coordinator Precision Twist Drill Company 301 Industrial Avenue
Crystal Lake, Illinois 60014
Dear Mr. Mullen:
Thank you for your letter of February
21, addressed to Secretary of Labor Elizabeth Dole, concerning
the new lockout/tagout standard, 29 CFR 1910.147. Please excuse
the delay in our response.
Normal production operations, such
as tool changes, cleaning, unjamming, servicing and making
adjustments to machines, which are routine, repetitive and
integral to the use of the equipment for production are not
covered by the requirements of 29 CFR 1910.147, if the work
is performed using alternative protective measures which ensure
employee safety. Lockout or tagout is not required by this
standard if the employer can demonstrate that the alternative
means enable employees to service the machine without being
exposed to unexpected activation of the equipment or release
of stored energy. Production safeguards conforming to the
requirements of 29 CFR 1910, Subpart O, and the applicable
American National Standards Institute (ANSI) standard which
provide for control of, or safeguarding from, hazardous energy
release(s) and which are not bypassed or rendered ineffective
are acceptable alternative means of protection. Typical ANSI
standards which contain such provisions are listed in the
enclosure, which is not all inclusive.
29 CFR 1910.147 specifically addresses
practices and procedures that are necessary to disable machinery
or equipment to prevent the release of potentially hazardous
energy while maintenance and servicing activities are being
performed by employees. Servicing and maintenance functions,
normally conducted by the machine or process equipment operator
and for which safeguarding provisions in compliance with Subpart
O ensure hazardous energy control, are regulated by 29 CFR
1910.147 whenever the normal machine safeguarding is ineffective
or rendered ineffective.
It is not apparent, from the information
provided with your letter, that your normal operator machine
safety guards and/or devices provide for protection of set-up
persons from the inadvertent energization of machine components.
If the normal operator safety guards and/or devices assure
employee protection from unexpected machine component energization
during set-up procedures, the standard at 29 CFR 1910.147
would not be applicable. However, if such protection is not
assured and it is your intent to provide for compliance with
the lockout/tagout standard through implementation of the
enclosed set-up procedure, our review identified serious deficiencies.
In order to provide further guidance regarding your obligations
under the new lockout/tagout standard we offer the following
The standard at 29 CFR 1910.147(c)(4)
requires that procedures be developed, documented and utilized
for the control of potentially hazardous energy. The procedures
must clearly outline the scope, purpose, authorization, rules
and techniques to be used. The procedures must identify each
specific equipment and it's unique energy isolation requirements.
(Generic procedures are permitted for similar equipment.)
Energy isolation devices must be identified as well as the
procedures for shut-down, lockout/tagout and deenergization
verification. Operators who are required and/or permitted
to engage in maintenance/servicing functions requiring lockout/tagout
are designated as "authorized employees" and must receive
comprehensive training regarding the mandatory procedures
for lockout/tagout as required at 29 CFR 1910.147(c)(7).
Prior to beginning maintenance/servicing
operations, the equipment must be deenergized and locked-out
or tagged-out as required at 29 CFR 1910.147(c)(5), (c)(7),
and (d). All potentially hazardous energy sources must be
deenergized, therefore all pressurized air supplies (air lines),
or other energy sources, must also be controlled.
In the event that a tagout procedure
is to be used, the standard requires more extensive procedures
than those required if lockout is used. Please refer to 29
CFR 1910.147(c)(2),(c)(3),(c)(5), and (d)(4).
A copy of the standard is enclosed.
If we may be of further assistance please contact us.
Gerard F. Scannell Assistant Secretary