- Record Type:
Interpretation
- Standard Number: 1910.147
- Subject: Lockout/Tagout
with regards to the cleanup and sanitizing of machinery
and equipment in the meatpacking industry.
- Information Date: 1991
July 29, 1991
Mr. William E. Funcheon, Jr. &
Associates
RR 2 Box 419F
Monticello, Indiana 47960
Dear Mr. Funcheon:
This is in further response to your
undated letter that we received on May 24, in which you asked
if the Occupational Safety and Health Administration (OSHA)
requires point of operation guards and/or lockouts to be in
place during the cleanup and sanitizing of machinery and equipment
in the meat packing industry.
The answer to your first question
is yes; OSHA requires that effective safeguards be in place
for the protection of the employees engaged in both the operation,
as well as cleanup and sanitizing, of machinery and equipment
in the meat packing industry. Section 29 CFR 1910.147, the
Control of Hazardous Energy (Lockout/Tagout) standard, covers
the servicing and maintenance of machines and equipment in
which the unexpected energization or start up of the machines
or equipment, or release of stored energy, could cause injury
to employees. Normal production operations are not covered
by this standard unless during the servicing and/or maintenance,
which takes place during normal production operations, the
employee performing the servicing may be subjected to hazards
that are not encountered as part of the production operation
itself. This situation would occur if the employee must either
remove or bypass machine guards or other safety devices, resulting
in exposure to hazards at the point of operation, if the employee
is required to place any part of his or her body in contact
with the point of operation of the operational machine or
piece of equipment, or finally, if the employee is required
to place any part of his or her body into a danger zone associated
with a machine operating cycle. If any of the above mentioned
situations exist, then the provisions of the lockout/tagout
standard would apply.
A note to paragraph (a)(2)(ii)(B)
of the standard does provide a limited exception for minor
servicing activities which take place during normal production
operations, but only if these activities are routine, repetitive,
and integral to the use of the equipment for production, and
provided that the work is performed using alternative measures
which provide effective protection.
In response to your second question,
the participation or degree of support given by Mr. Barry
White in the development of the lockout/tagout standard was
a part of the deliberative process that takes place during
the formulation of all standards. We have no record of and
are unable to characterize at this time the extent or nature
of his support for the standard.
If you should need additional assistance,
please contact us again.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs
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