Minor Servicing, Maintenance- Routine, Repetitive, Integral To Use- Lockout Not Mandatory

Guest Post by Julie O’Keefe, Partner, Armstrong Teasdale LLP

PMPA member companies are engaged in making parts that require precision during the machining process of a specific customer order.  This necessitates multiple  routine adjustments being made throughout the shift.  It can involve changing a dulled drill bit or insert on a screw machine or CNC, it could be redirecting a coolant line that vibrated out of place. It can involve  adjusting the alignment of a tool multiple times  to maintain the needed offset or location.

These kinds of adjustments are routine, repetitive, and integral to the use of the equipment for production. They are necessary so that the parts are produced to the required precision.  This is the classic type of  situation intended to be addressed by the exception to the LOTO standard, 1910.147(a)(2)(ii)(B) , assuming the worker does these things using alternative measures that provide alternate protection.

Many inspectors do not recognize that this kind of minor servicing, maintenance which is routine, repetitive and integral to the use of the equipment for production is an allowable exception to the Lockout Tagout requirements if the worker is protected by alternate means.

One form of alternate protection may be, according to interpretations published on OSHA’s website (see below for one of several examples), stopping the machine using a control switch (not an energy isolating switch, just a control switch), if the switch is designed in accordance with good engineering practice, controls all the hazardous energy and is placed in the off position, and is under the exclusive control of the employee performing the task.

Effective protection can include control switches according to OSHA.

Kershaw Letter Interpretation:

“…minor tool changes and adjustments, which are routine and repetitive and must be
performed as an integral part of the production process, are permitted to be
performed without LOTO if the work is performed using alternative
measures that provide effective protection. Electric disconnect switches or
control switches are considered effective protection if the
switches:

  1. Are properly designed and applied in accordance with recognized and good
    engineering practice; and
  2. Control all the hazardous energy and are placed in an off
    position
    ; and
  3. Are under the exclusive control of the employee performing the
    task.

Kershaw Interpretation

Here is a quote from the Federal register Vol. 54,No. 169 Friday September 1, 1989:

“As was discussed in the preamble to the proposal, OSHA
recognizes that some servicing operations must be performed with the power on;
in these situations, it would not make sense to to require lockout or tagout,
which apply to deenergized equipment.”

Minor servicing or maintenance that is routine, repetitive and
integral to the use of the equipment for production may be covered by alternate protection. As the interpretations on the OSHA website indicate, such effective protection can include stopping the machine using a control switch (not an energy isolating switch, just a control switch), if the
switch is designed in accordance with good engineering practice, controls all the hazardous energy and is placed in the off position, and is under the exclusive control of the employee performing the task.

Guest Post by Julie O’Keefe, Partner, Armstrong Teasdale LLP

www.armstrongteasdale.com

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