Document DD42zNZREG7K68rzJoMq2Rje4

TO: Distribution Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles June 18, 1991 LOCK-OUT/TAG-OUT STANDING TGG:FGJ: /VC: AJO: RF XF:22-Sli Attached is the OSHA compliance guideline for the lock-out standard. This can be used as a basis to evaluate your existing programs, as an indication of what to expect if OSHA shows up. M o----------------- T. G. Grumbles dlj Attachment Distribution: SAFETY DIRECTORS Bruce Trego-Aber, Brent White-Bait, George Williams-Blane, Matt Tonkovich-Hmd, K. L. Fogg-LCCP, R. V. Gantz-LCLAB, G. M. ShirleyLCVCM, Mike Lunsford-Okc, Greg Lipps-Premiere, R. B. Martin-Austin, J. R. Drumwright, Rick Quy VVV 000006425 21:6322 OSHA INSTRUCTION STD 1-7.3 September 11,1990 Subject: 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout) -- Inspection Procedures and Interpretive Guidance A. Purpose. This instruction establishes policies and provides clarification to ensure uniform enforcement of the Lockout/Tagout Standard. B. Scope. This instruction applies OSHA-wide. C. References. 1. General Industry Standards, 29 CFR 1910, Subpart O, Subpart S, and other specific subparts. 2. OSHA Instruction CPL 2.45B, June 15, 1989, the Revised Field Operations Manual (FOM). D. Effective Date of Requirements. All requirements of 29 CFR 1910.147 have an effective date of January 2, 1990. The information collection requirements contained in this section have been approved by the Office of Management and Budget (OMB) and listed under OMB control number 1218-0150, as announced at Federal Register, Volume 54, No. 199, October 17, 1989. E. Action. Regional Administrators and Area Direc tors shall ensure that the guidelines and interpretive guidance in this instruction are followed and that com pliance officers are familiar with the contents of the standard. F. Federal Program Change. This instruction de scribes a Federal program change which affects State programs. Each Regional Administrator shall: REFERENCE FILE 1. Ensure that this change is forwarded to each State designee. 2. Explain the technical content of this change to the State designee as requested. 3. Ensure that State designees acknowledge receipt of this Federal program change in writing, within 30 days of notification, to the Regional Administrator. This ac knowledgment should include the State's intention to follow the inspection guidelines described in this instruc tion, or a description of the State's alternative guidelines which are "at least as effective" as the Federal guidelines. a. If a State intends to follow the revised inspection guidelines described in this instruction, the State must submit either a revised version of this instruction, adapt ed as appropriate to reference State law, regulations and administrative structure, or a cover sheet describing how references in this instruction correspond to the State's structure. The State's acknowledgment letter may fulfill the plan supplement requirement if the appropriate doc umentation is provided. b. Any alternative State inspection guidelines must be submitted as a State plan supplement within 6 months. If the State adopts an alternative to Federal guidelines, the State's submission must identify and provide a ratio nale for all substantial differences from Federal guide lines in order for OSHA to judge whether a different State guideline is as effective as a comparable Federal guideline. 4. After Regional review of the State plan supplement and resolution of any comments thereon, forward the State submission to the National Office in accordance with established procedures. The Regional Administra tor shall provide a judgment on the relative effectiveness of each substantial difference in the State plan change and an overall assessment thereof with a recommenda tion for approval or disapproval by the Assistant Secretary. 5. Review policies, instructions and guidelines issued by the State to determine that this change has been communicated to State personnel. G. Background. The Standard for Control of Hazard ous Energy (Lockout/Tagout), 29 CFR 1910.147, was promulgated on September 1, 1989, at Federal Register, Volume 54, No. 169 (pages 36644-36696), and was effective on January 2, 1990, as announced at Federal Register, Volume 54, No. 213, November 6, 1989 (page 46610). Previously existing section 29 CFR 1910.147 was redesignated as 29 CFR 1910.150, Sources of Standards. 1. Since the inception of its enforcement program, OSHA has relied on the "General Duty Clause" (Sec tion 5(a)(1) of the OSH Act) to ensure that employers safeguarded their maintenance and service employees VVV 000006426 Occupational Safety & Health Reporter 4 OSHA STANDARD DIRECTIVES through the use of lockout/tagout from the hazards involving the unintentional release of hazardous energy. Such violations reached a level so significant that the development and promulgation of a lockout/tagout standard was required. 2. The new rule addresses practices and procedures that are necessary to disable machinery or equipment and to prevent the release of potentially hazardous energy while maintenance and servicing activities are being performed. 3. The lockout/tagout provisions of this standard are for the protection of general industry workers while performing servicing and maintenance functions and augment the safeguards specified at Subparts O, S, and other applicable portions of 29 CFR 1910. H. Inspection Guidelines. The standard incorporates performance requirements which allow employers flexi bility in developing lockout/tagout programs suitable for their particular facilities. I. The compliance officer shall determine whether servicing and maintenance operations are performed by the employees. If so, the compliance officer shall further determine whether the servicing and maintenance oper ations are covered by 29 CFR 1910.147 or by the requirements or employee safeguarding specified by oth er standards as discussed in 1.1. 2. Evaluations of compliance with 29 CFR 1910.147 shall be conducted during all general industry inspec tions within the scope of the standard in accordance with the FOM, Chapter III, D.7. and 8., Additional Informa tion to Supplement Records Review. The review of records shall include special attention to injuries related to maintenance and servicing operations. 3. The compliance officer shall evaluate the employ er's compliance with the specific requirements of the standard. The following guidance provides a general framework to assist the compliance officer during inspections: a. Ask the employer for any hazard analysis or other basis on which the program related to the standard was developed. Although this is not a specific requirement of the standard, such information, when provided, will aid in determining the adequacy of the program. It should be noted that the absence of a hazard analysis does not indicate non-compliance with the standard. b. Ask the employer for the documentation including: procedures for the control of hazardous energy including shutdown, equipment isolation, lockout/tagout applica tion, release of stored energy, verification of isolation; certification of periodic inspections; and certification of training. The documented procedure must identify the specific types of energy to be controlled and, in instances where a common procedure is to be used, the specific S-250 21:8323 equipment covered by the common procedure must be identified at least by type and location. The identifica tion of the energy to be controlled may be by magnitude and type of energy. Note the exception to documentation requirements at paragraph 191Q.147(c)(4)(i), "Note". The employer need not document the required prncqrinre for a particular machine or equipment jtffien all eight (8 elements listed in the "Note" exist. c. Evaluate the employer's training programs for "au thorized", "affected", and "other" employees. Interview a representative sampling of selected employees as a part of this evaluation (29 CFR 1910.147(c)(7)(i)). (1) Verify that the training of authorized employees includes: (a) Recognition of hazardous energy; (b) Type and magnitude of energy found in the workplace; (c) The means and methods of isolating and/or con trolling energy; and (d) The means of verification of effective energy control, and the purpose of the procedures to be used. (2) Verify that affected employees have been instruct ed in the purpose and use of the energy control procedures. (3) Verify that all other employees who may be affected by the energy control procedures are instructed about the procedure and the prohibition relating to attempts to restart or reenergize such machines or equipment. (4) When the employer's procedures permit the use of tagout, the training of authorized, affected, and other employees shall include the provisions of 29 CFR 1910.l47(c)(7)(ii) and (d)(4)(iii), d. Evaluate the employer's manner of enforcing the program (29 CFR 1910.147(c)(4)(H)). 4. In the event that deficiencies are identified by following the guidelines in H.3. of this instruction, the compliance officer shall evaluate the employer's compli ance with specific requirements of the standard, with particular attention to the interpretive guidance provided in section I. and to the following: a. Evaluate compliance with the requirements for periodic inspection of procedures. b. Ensure that the person performing the periodic inspection is an authorized employee other than the one(s) utilizing the procedure being inspected. c. Evaluate compliance with retraining requirements which result from the periodic inspection of procedures and practices, or from changes in equipment/processes. d. Evaluate the employer's procedures for assessment, and correction of deviations or inadequacies identified during periodic inspections of the energy control procedure. WV GOOOOfc^27 10-24-90 Published by THE BUREAU OF NATIONAL AFFAIRS, INC., Washington, D.C. 20037 5 21:8324 e. Identify the procedures for release from lockout/ tagout, including: (1) Replacement of safeguards, machine or equipment inspection, and removal of non-essential tools and equipment; (2) Safe positioning of employees; (3) Removal of lockout/tagout device(s); and (4) Notification of affected employees that servicing and maintenance is completed. f. Ensure that when group lockout or tagout is used, it affords a level of protection equivalent to individual lockout or tagout as amplified in 1.7, through 1.9. of this instruction. 5. The lockout/tagout standard is a performance standard; therefore, additional guidance is provided in Appendix C of this instruction to assist in effective implementation by employers and for uniform enforce ment by OSHA field staff. I. Interpretive Guidance. The following guidance rela tive to specific provisions of 29 CFR 1910.147 is pro vided to assist compliance officers in conducting inspec tions where the standard may be applicable: 1. Scope of the Standard. a. The standard as specified in 29 CFR 1910.147(b), applies to any source of mechanical, hydraulic, pneumat ic, chemical, thermal, or other energy. (1) The standard applies to piping systems, and re quires, at 29 CFR 1910.147(d)(5), that all potentially hazardous stored or residual energy be relieved, discon nected, restrained, and otherwise rendered safe. If there is a possibility of reaccumulation of stored energy to a hazardous level, continued monitoring shall be per formed while a potential hazard exists. (2) The standard also applies to high intensity electro magnetic fields regulated at 29 CFR 1910.97, nonioniz ing radiation. Such electromagnetic devices shall be deenergized and held off whenever workers are present within a high intensity ambient field. (3) Servicing/maintenance of fire alarm and extin guishing systems and their components, upon which other employees are dependent for fire safety, are not required to meet the requirements of this standard if the workers performing servicing/maintenance upon fire ex tinguishing systems are protected from hazards related to the unexpected release of hazardous energy by appro priate alternative measures. (See 29 CFR 1910, Subpart L.) b. The standard does not apply to servicing and maintenance when employees are not exposed to the unexpected release of hazardous energy. c. Safeguarding workers from the hazards of contact ing electrically live parts (exposure to electric current) continues to be regulated at Subpart S. REFERENCE FILE d. Servicing and maintenance functions conducted during normal production operations are not regulated at 29 CFR 1910.147 if the safeguarding provisions of Subpart O or other applicable portions of 29 CFR 1910 prevent worker exposure to hazards created by the unex pected energization or start-up of the machine or equip ment. However, lockout/tagout procedures are required if the production safeguards are rendered ineffective while an employee is exposed to hazardous portions of the machines or equipment. e. Generally, activities such as lubrication, cleaning or unjamming, servicing of machines or equipment, and making adjustments or tool changes, where the employee may be exposed to the UNEXPECTED energization or start-up of the equipment or release of hazardous energy, are covered by this standard. However, minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of equipment for production, and if work is performed using alterna tive protective measures which provide effective employ ee protection. Thus, lockout or tagout is not required by this standard if the alternative protective measures en able the servicing employee to clean or unjam, or other wise service the machine without being exposed to unex pected energization or activation of the equipment, or the release of stored energy. NOTE: Appendix C, section A, provides further guid ance in this area. f. The exclusion of plug and cord connected electric equipment, at 29 CFR 1910.147(a)(2)(iii)(A), applies only when the equipment is unplugged and the plug is under the exclusive control of the employee performing the servicing and/or maintenance. (1) The plug is under the exclusive control of the employee if it is physically in the possession of the employee, or in arm's reach and in line of sight of the employee, or if the employee has affixed a lockout/ tagout device on the plug. (2) The company lockout/tagout procedures required by the standard at 29 CFR 1910.147(c)(4) shall specify the acceptable procedure for handling cord and plug connected equipment. 2. Procedures. a. The employer must develop and document proce dures and techniques to be used for the control of hazardous energy. The standard, at 29 CFR 1910.147(c)(4)(i) "Note," identifies eight (8) conditions that must exist in order to excuse the employer's obliga tion to maintain a written procedure for a specific machine or piece of equipment. b. 29 CFR 1910.147(d)(3) and (d)(5) provide that Occupational Safety & Health Reporter VVV 000006428 OSHA STANDARD DIRECTIVES energy isolation be a mandatory part of the employer's control procedure where either a lockout system or a tagout system is used. c. Similar machines and/or equipment (such as those using the same type and magnitude of energy and the same or similar types of controls) can be covered with a single written procedure. 3. Lockout vs. Tagout. a. OSHA has determined that lockout is a surer means of ensuring deenergization of equipment than tagout, and that it is the preferred method. b. 29 CFR 1910.147(c)(3)(ii) provides that: When using a tagout program in those instances where the equipment is capable of being locked out, the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained when using a lockout program. Additional means beyond those neces sary for lockout are required. (Additional means include: additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.) c. 29 CFR 1910.147(c)(4)(H) provides that: Where lockout/tagout programs are used, the employer is re quired to implement an effective means of enforcing the program. d. 29 CFR 1910.147(c)(7)(ii)(A-F) provide that: Ad ditional training of authorized, affected and other em ployees is required when tagout programs are used. e. 29 CFR 1910.147(c)(5)(ii)(A) requires that lock out and tagout devices be capable of withstanding the environment to which they are exposed. Devices which are not exposed to harsh environments need not be capable of withstanding such exposure. f. 29 CFR 1910.147(c)(5)(ii)(C)(2) requires that tag out devices having reusable, non-locking, easily detach able means of attachment (such as string, cord, or adhesive) are not permitted. 4. Employees and Training. a. The standard recognizes three types of employees: (1) "authorized" and (2) "affected", defined in 1910.147(b), and (3) "other", defined in 1910.147 (c)(7)(ii)(C). Different levels of training are required based upon the respective roles of employees in the control of energy and the knowledge which they must possess to accomplish their tasks safely and to ensure the safety of fellow workers as related to the lockout/tagout procedures (1910.147(c)(7)(i)). b. Employees who exclusively perform functions relat ed to normal production operations, and who perform servicing and/or maintenance under the protection of normal machine safeguarding, need only be trained as S-250 21:8325 "affected" (rather than "authorized") employees even if tagout procedures are used. (See, I.l.d. and I.l.e. of this instruction.) c. The employer's training program must cover, at a minimum, the following three areas: energy control pro gram, elements of energy control procedures relevant to employee duties, and the pertinent requirements of the standard (1910.147(c)(7) and (d) through (f)). d. The employer must provide: (1) Effective initial training; (2) Effective retraining as needed; and (3) Certification of training. The certification shall contain each employee's name and dates of training (1910.147 (c)(7) (iv)). e. Retraining of authorized and affected employees is required: (1) Whenever there is a change in employee job assignments; (2) Whenever a new hazard is introduced due to a change in machines, equipment or process; (3) Whenever there is a change in the energy control procedures; or (4) Whenever a periodic inspection by the employer reveals inadequacies in the company procedures or in the knowledge of the employees. 5. Periodic Inspection by the Employer a. At least annually, the employer shall ensure that an authorized employee other than the one(s) utilizing the energy control procedure being inspected, is required to inspect and verify the effectiveness of the company energy control procedures. These inspections shall at least provide for a demonstration of the procedures and may be implemented through random audits and planned visual observations. These inspections are in tended to ensure that the energy control procedures are being properly implemented and to provide an essential check on the continued utilization of the procedures (29 CFR 1910.147 (c)(6)(i)). (1) When lockout is used, the employer's inspection shall include a review of the responsibilities of each authorized employee implementing the procedure with that employee. Group meetings between the authorized employee who is performing the inspection and all au thorized employees who implement the procedure would constitute compliance with this requirement. (2) When tagout is used, the employer shall conduct this review with each affected and authorized employee. (3) Energy control procedures used less frequently than once a year need be inspected only when used. b. The periodic inspection must provide for and ensure effective correction of identified deficiencies (29 CFR 1910.147(c)(6)(i)(B)). WV 000006429 10-24-90 Published by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington, D.C. 20037 7 21:8326 c. The employer is required to certify that the pre scribed periodic inspections have been performed (29 CFR 1910.147(c)(6)(ii)). 6. Equipment Testing or Positioning. Under 29 CFR 1910.147(0(1), OSHA allows the temporary removal of lockout or tagout devices and the reenergization of the machine or equipment ONLY during the limited time necessary for the testing or positioning of machines, equipment or components. After the completion of the temporary reenergization, the authorized employees shall again deenergize the equipment and resume lock out/tagout procedures. 7. Group Lockout/Tagout. Group lockout/tagout pro cedures shall be tailored to the specific industrial oper ation and may be unique in the manner that employee protection from the release of hazardous energy is achieved. Irrespective of the situation, the requirements of this generic standard specify that each employee performing maintenance or servicing activities shall be in control of hazardous energy during his/her period of exposure. a. Group operations normally require that a lockout/ tagout program be implemented which ensure that each authorized employee is protected from the unexpected release of hazardous energy by his/her personal lockout/ tagout device(s). No employee may affix the personal lockout/tagout device of another employee. Various group lockout/tagout procedures discussed in Appendix C provide for each authorized employee's use of his/her personal lockout/tagout device(s). b. One of the most difficult problems addressed by the standard involves the servicing and maintenance of com plex equipment. Such equipment is frequently used in the petrochemical and chemical industries. Acceptable group lockout/tagout procedures for complex equipment are discussed further at Appendix C. 8.Compliance with Group Lockout/Tagout. These operations shall, at a minimum, provide for the following: a. Before the machine or equipment is shut down, each authorized employee who is to be involved during the servicing/maintenance operation shall be made aware by the employer of the type, magnitude, and hazards related to the energy to be controlled and of the method or means to control the energy. In the event that the machine or equipment is already shut down, the authorized employee shall be made aware of these ele ments before beginning his/her work (29 CFR 1910.147(d)(1)). Verification shall be performed as not ed at I.8.f. of this instruction. b. An orderly shutdown of the machine or equipment shall be conducted which conforms to the documented company procedure and which will not create hazards (29 CFR 1910.147(d)(2)). REFERENCE FILE c. All energy isolating devices needed to isolate the machine or equipment shall be effectively positioned and/or installed (29 CFR 1910.147(d)(3)). d. The authorized employee(s) performing the servic ing or maintenance (following the company procedure) shall personally affix a lock or tag upon each energy isolating device (29 CFR 1910.l47(d)(4)(i). The com pany procedure must ensure that no employee affixes a personal lockout/tagout device for another employee. (1) A single lock upon each energy isolating device, together with the use of a lockbox for retention of the keys and to which each authorized employee affixes his/her personal lock or tag, also satisfies the require ment (29 CFR 1910.147(f)(3)(i. (2) Locks shall be affixed in a manner that will hold the energy isolating device in a safe (off) position (29 CFR 1910.147(d)(4)(ii)). (3) Tagout devices, where used, shall be affixed at the same location as would a lock if such fittings are pro vided, or shall be affixed in a manner that will clearly indicate that movement of the isolating device is prohib ited (29 CFR 1910,147(d)(4)(iii. e. Following the application of locks or tags, all potentially hazardous stored energy or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe (29 CFR 1910.147(d)(5)(i)). (1) Verification of energy isolation shall be monitored as frequently as necessary if there is a possibility of reaccumulation of stored energy (29 CFR 1910.147(d) (5)(ii. (2) Monitoring may be accomplished, for example, by observation or with the aid of a monitoring device which will sound an alarm if a hazardous energy level is being approached. f. Authorized employees shall verify that isolation and deenergization have been effectively accomplished be fore starting servicing/maintenance work. Verification is also necessary by each group of workers before starting work at shift changes. g. Release from lockout/tagout shall be accomplished in compliance with the requirements at 29 CFR 1910.147(e). (1) The machine or equipment area shall be cleared of nonessential items to prevent malfunctions which could result in employee injuries (29 CFR 1910.147(e)(1)). (2) The authorized employees shall remove their re spective locks or tags from the energy isolating devices or from the group lockbox(s) following the procedure established by the company (29 CFR 1910.147(e)(3)). (3) In all instances, the company procedure must provide a system which identifies each authorized em ployee involved in the servicing/maintenance operation. (4) Before reenergization, all employees in the ma chine or equipment area shall be safely positioned or VVV 000006A30 Occupations! Safety & Health Reporter B OSHA STANDARD DIRECTIVES moved from the area, and the affected employees shall be notified that the lockout/tagout devices have been removed (29 CFR 1910.147(e)(2)). h. During all group lockout/tagout operations where the release of hazardous energy is possible, each author ized employee performing servicing or maintenance shall be protected by his/her personal lockout or tagout device and by the company procedure. As described at Appen dix C, B.l.g., a master tag is a personal tagout device if each employee personally signs on and signs off on it and if the lag dearly identifies each authorized employee who is being protected by it. 9. Compliance of Outside Personnel. Outside servicing and maintenance personnel (contractors, etc.) engaged in activities regulated under 29 CFR 1910.147 are subject to the requirements of that standard. a. The CSHO shall verify that the outside employer and the on-site employer have exchanged information regarding the lockout/tagout energy control procedures used by each employer's workers (29 CFR 1910,147(f)(2)(i)). b. The CSHO shall verify that the on-site employer has effectively informed his/her personnel of the restric tions and prohibitions associated with the outside em ployer's energy control procedures (29 CFR 1910.147(f)(2)(H)). c. When an outside employer is engaged in servicing and maintenance activities within an on-site employer's facility and if that contractor's activities are subject to the requirements of 29 CFR 1910.147, the CSHO shall coordinate with the Area Director to obtain permission to initiate an independent inspection of the outside contractor's activities. 10. Appendix B contains an example of a functional flow diagram to implement safe lockout/tagout proce dures. This flow diagram is presented solely as an aid and does not constitute the exclusive or definitive means of complying with the standard in any particular situation. J. Classification of Violations. 1. A deficiency in the employer's energy control pro gram and/or procedure that could contribute to a poten tial exposure capable of producing serious physical harm or death shall be cited as a serious violation. 2. The failure to train "authorized", "affected", and "other" employees as required for their respective classi fications should normally be cited as a serious violation. 3. Paperwork deficiencies in lockout/tagout programs where effective lockout/tagout work procedures are in place shall be cited as other-lhan-serious. K. Evaluation. In keeping with agency policy, each Region shall evaluate the effectiveness of the guidance in this instruction annually. Each Regional Administrator shall submit a written evaluation report to the Director ate of Compliance Programs within 30 days of the close of the fiscal year. S-251 21:6327 Appendix A The following listing indicates a number of OSHA standards which currently impose lockout/tagout related requirements, The list does not necessarily include all lockout/tagout related OSHA 29 CFR 1910 standards. Powered Industrial Trucks 1910.178(q)(4) Overhead and Gantry Cranes 1910.179(g)(5)(i), (ii), (Hi) I910.179(l)(2)(i)(c), (d) Derricks 1910.181(f)(2)(i)(c), (d) Woodworking Machinery 1910.213(a>( 10) 1910.213(b)(5) Mechanical Power Presses I910.217(b)(8)(i) 1910.2l7(d)(9)(iv) Forging Machines 1910.218(a)(3)(iii), (iv) 1910.218(d)(2) 1910.218(e)(1)(H), (iii) 1910.218(0(1)0), (i), (Hi) 1910.218(0(2)0), (ii) 1910.218(h)(2), (5) 1910.218(0(1), (2) I910.218(j)(l) Welding, Cutting and Brazing 1910.252(c)(l)(i) Pulp, Paper and Paperboard Mills 1910.261(b)(4) 1910.261(0(6)0) 19l0.261(g)(15)(i) 1910.261 (g)(19)(iii) 1910.261(j)(4)(iii) 1910.261 (j)(5)(iii) 1910.261(k)(2)(ii) Textiles 1910.262(c)(1) 1910.262(n)(2) 1910.262(p)(l) 1910.262(q)(2) Bakery Equipment 1910.263(!)(3)(iii)(b), 1910.263(l)(8)(Hi) Sawmills 19 10.265(c)(1 2)(v), 1910.265(c)(13), I910.265(c)(26)(v) Grain Handling 1910.272(e)(l)(ii) 1910.272(g)(l)(ii) 1910.272(0(4) Electrical !9l0.3050)(4)(ii)(A), 1910.205(j)(4)(ii)(C)(l) VVV 000006431 11-21-90 Published by THE BUREAU OF NATIONAL AFFAJRS, INC., Washington. D.C. 20037 51 21:8328 Appendix B This flow diagram does not constitute the exclusive or definitive means of complying with the standard in any par ticular situation and is presented solely as an aid. IXAKTLt - rUVCTlOWAC. fLON 0 [XCKAJt fOX SMrttHZHtXTlO" Of LOCKOUT ! TACOUT XZ0V1*Z*STI REFERENCE FILE CONDUCT HACKlHI/rAOCESt HAIARD ANALX31I * movjoi THAiNjMc n Arrtcrro imiiotkii DEVILOR DOCUMENTED LOCKOUTfTASOUT MOCEKUM* DCVtLOR TKAtHDK PROGRAM TROVIOE OCT I LED TRAINING TO AUTHOR!! 0 EMRIOTEI! ASSICH KkSNT./ICV[Ct TAM TO AUTHORTUO IMRLOTEtl _______ *_________ RROVIOE TRAINING TO ALL OTHER EAR LOTEt! PROCEDURE* DOCUMENT MOtjrr ArrEcreo AAlNT/llRVtCt Of! xecMTiry INIRST IHUT1K DEVICE! letMttrt a oitain LOCKOUT/TAGOUT DIV1CII DEACTIVATE * TAGOUT DEACTIVATE A LOCKOUT HA1AADOVI BNCACT HOT CONTROLLED VERITY NAIAADOO! tHEAGY CONTROLLED "CyZD RCRfOAH TAM Perua* cuitoot or coviTNzrr TO ArrtCTtO tKVIOTtEISI PXTPI CVt TOOL! | EGUUME*/ VERTfl RtRACNNEL CLtAI AND ACCOUNTED ro RlWVt LOCROUT/TAGOUT device! HOT IfT ArrtCTES iruim REITORf POWER R ?-------------------------------------- ----------------- ^ /. RPOILEM lerNTirilS 22 Occupational Safety & Health Reporter VVV 000006432 52 OSHA STANDARD DIRECTIVES Appendix C This appendix provides guidelines to assist the compli ance officer during evaluations of employer operations. A. Normal Production Operations. The lockout/tagout standard, 29 CFR 1910.147, addresses the safety of employees engaged in servicing and maintenance activi ties in general industry workplaces, The standard com plements the requirements for machine and process oper ator safety prescribed by the various general industry standards in 29 CFR Part 1910. Subpart O of 29 CFR 1910 provides the principal, though not exclusive, ma chine guarding requirements. 1. Safeguarding of servicing and maintenance workers can be ensured either by: a. Effective machine safeguarding in compliance with Subpart O, or b. Compliance with 29 CFR 1910.147 in situations where the normal production operations safeguards are rendered ineffective or do not protect the servicing/ maintenance worker. 2. Activities which are routine, repetitive, and integral to the use of equipment for production are not covered by this standard if alternative measures provide effective worker protection from hazards associated with unex pected energization. Compliance with the machine guarding requirements of Subpart O is an example of such alernative measures. In addition, supplemental per sonal protective equipment may be necessary during a servicing or maintenance operation when a toxic sub stance is to be isolated. Under such circumstances, the requirements of applicable standards, such as 29 CFR 1910.134 Subpart Z, also must be met. 3. An employer who requires employees to perform routine maintenance and/or servicing while a machine or process is operating in the production mode, must provide employee safeguarding under the applicable re quirements of Subpart O. (Ref. 29 CFR 1910.212 (a) (l)). Operations such as lubricating, draining sumps, servicing of filters, and inspection for leaks and/or mechanical malfunction are examples of routine oper ations which often can be accomplished with effective production-mode safeguards. However, the replacement of machine or process equipment components such as valves, gauges, linkages, support structure, etc., is not considered to be a normal routine maintenance function which can safely be accomplished during machine or process equipment operation. Such maintenance requires energy isolation and should be evaluated by OSHA field staff. They also may be an appropriate subject of a variance request. 4. Several alternative means of safeguarding the haz ardous portions of machines and equipment are present S-251 21:8329 ed by the national consensus standard, ANSI BU. 19-1990. Although that standard is not all inclu sive, it describes effective safeguarding alternatives for the protection of employees. The safeguards described include: interlocked barrier guards, presence sensing devices and various devices under the exclusive control of the employee. Such devices or guards, properly ap plied, may be used in clearing minor jams and perform ing other minor servicing functions which occur during normal production operations and which meet the crite ria described in paragraph A.2. of this appendix. B. Group Lockout/Tagout. The group lockout/tagout procedures described in this instruction at paragraph 1.8. require each authorized employee to be in control of potentially hazardous energy release during their servic ing/maintenance work assignments. Under most circum stances, where servicing/maintenance is to be conducted during only one shift by an individual or a small number of persons working together, the installation of each individual's lockout/tagout device upon each energy iso lating device would not be a burdensome procedure. However, when many energy sources or many persons are involved, and/or the procedure is to extend over more than one shift, (possibly several days, or weeks) consideration must be given to the implementation of a lockout/tagout procedure that will ensure the safety of the employees involved and will provide for each individ ual's control of the energy hazards. The following proce dures are presented as examples to illustrate the imple mentation of a group lockout/tagout procedure involving many energy isolating devices and/or many servicing/maintenance personnel. They illustrate several alterna tives for having authorized employees affix personal lockout/tagout devices in a group lockout/tagout set ting. These examples are not intended to represent the only acceptable procedures for conducting group operations. 1. Definitions. Various terms used in the examples are defined below. a. PRIMARY AUTHORIZED EMPLOYEE is the authorized employee who exercises overall responsibility for adherence to the company Iockout/tagout procedure. (See 29 CFR 1910.147 (0 (3) (ii) (A).) b. PRINCIPAL AUTHORIZED EMPLOYEE is an authorized employee who oversees or leads a group of servicing/maintenance workers (e.g., plumbers, carpen ters, electricians, metal workers, mechanics). c. JOB-LOCK is a device used to ensure the continu ity of energy isolation during a multi-shift operation. It is placed upon a lock-box. A key to the job-lock is controlled by each assigned primary authorized employ ee from each shift. VVV 000006433 11-21-90 Published by THE BUREAU OF NATIONAL AFFAIRS, INC., Washington. O.C. 20037 53 21:8330 d. JOB-TAG with TAB is a special tag for tagout of energy isolating devices during group lockout/tagout procedures. The tab of the tag is removed for insertion into the lock-box. The company procedure would require that the tagout job-tag cannot be removed until the tab is rejoined to it. e. MASTER LOCKBOX is the lockbox into which all keys and tabs from the lockout or tagout devices secur ing the machine or equipment are inserted and which would be secured by a "job-lock" during multi-shift operations. f. SATELLITE LOCKBOX is a secondary lockbox or lockboxes to which each authorized employee affixes his/her personal lock or tag. g. MASTER TAG is a document used as an adminis trative control and accountability device. This device is normally controlled by the operations department per sonnel and is a personal tagout device if each employee personally signs on and signs off on it and if the tag clearly identifies each authorized employee who is being protected by it. h. WORK PERMIT is a control document which authorizes specific tasks and procedures to be accomplished. 2. Organization. A group lockout/tagout procedure might provide the following basic organizational structure: a. A primary authorized employee would be designat ed. This employee would exercise primary responsibility for implementation and coordination of the lockout/ tagout of hazardous energy sources, for the equipment to be serviced. b. The primary authorized employee would coordinate with equipment operators before and after completion of servicing and maintenance operations which require lockout/tagout. c. A verification system would be implemented to ensure the continued isolation and deenergization of hazardous energy sources during maintenance and ser vicing operations. d. Each authorized employee would be assured of his/her right to verify individually that the hazardous energy has been isolated and/or deenergized. e. When more than one crew, craft, department, etc., is involved, each separate group of servicing/mainten ance personnel would be accounted for by a principal authorized employee from each group. Each principal employee is responsible to the primary authorized em ployee for maintaining accountability of each worker in that specific group in conformance with the company procedure. No person may sign on or sign off for another person, or attach or remove another person's lockout/ REFERENCE FILE tagout device, unless the provisions of the exception to 29 CFR 1910.147 (e) (3) are met. 3. Examples of Procedures for Group Lockout(Tagout. Examples are presented for the various methods of lockout/tagout using lockbox procedures. An example of an applicable method for complex process equipment is also presented. a. The following procedures address circumstances ranging from a small group of servicing/maintenance employees during a one-shift operation to a comprehen sive operation involving many workers over a longer period. (1) Type A. Each authorized employee places his/her personal lock or tag upon each energy isolating device and removes it upon departure from that assignment. Each authorized employee verifies or observes the deen ergization of the equipment. (2) Type B. Under a lockbox procedure, a lock or jobtag with tab is placed upon each energy isolation device after deenergization. The key(s) and removed tab(s) are then placed into a lockbox. Each authorized employee assigned to the job then affixes his/her personal lock or tag to the lockbox. As a member of a group, each assigned authorized employee verifies that all hazardous energy has been rendered safe. The lockout/tagout de vices cannot be removed or the energy isolating device turned on until the appropriate key or tab is matched to its lock or tag. (3) Type C. After each energy isolating device is locked/tagged out and the keys/tabs placed into a mas ter lockbox, each servicing/maintenance group "princi pal" authorized employee places his/her personal lock or tag upon the master lockbox. Then each principal au thorized employee inserts his/her key into a satellite lockbox to which each authorized employee in that specific group affixes his/her personal lock or tag. As a member of a group, each assigned authorized employee verifies that all hazardous energy has been rendered safe. Only after the servicing/maintenance functions of the specific subgroup have been concluded and the personal locks or tags of the respective employees have been removed from the satellite lockbox can the princi pal authorized employee remove his/her lock from the master lockbox. (4) Type D. During operations to be conducted over more than one shift (or even many days or weeks) a system such as described here might be used. Single locks/tags are affixed upon a lockbox by each author ized employee as described at Type B or Type C above. The master lockbox is first secured with a job-lock before subsequent locks by the principal authorized em- Occupational Safety & Health Reporter WV 000006434 54 OSHA STANDARD DIRECTIVES ployees are put in place on the master lockbox. The job!ock may have multiple keys if they are in the sole possession of the various primary authorized employees (one on each shift). As a member of a group, each assigned authorized employee verifies that all hazardous energy has been rendered safe. In this manner, the security provisions of the energy control system are maintained across shift changes while permitting reener gization of the equipment at any appropriate time or shift. b. Normal group lockout/tagout procedures require the affixing of individual lockout/tagout devices by each authorized employee to a group lockout device, as dis cussed in paragraph B.3.a. of this appendix. However, in the servicing and maintenance of sophisticated and com plex equipment, such as process equipment in petroleum refining, petroleum production, and chemical produc tion, there may be a need for adaptation and modifica tion of normal group lockout/tagout procedures in order to ensure the safety of the employees performing the servicing and maintenance. To provide greater worker safety through implementation of a more feasible sys tem, and to accommodate the special constraints of the standard's requirement for ensuring employees a level of protection equivalent to that provided by the use of a personal lockout or tagout device, an alternative proce dure may be implemented if the company documenta tion justifies it. Lockout/tagout, blanking, blocking, etc., is often supplemented in these situations by the use of work permits and a system of continuous worker ac countability. In evaluating whether the equipment being serviced or maintained is so complex as to necessitate a departure from the normal group lockout/tagout proce dures (discussed in paragraph B.3.a.), to the use of an alternative procedure as set forth below, the following factors (often occurring simultaneously) are some of those which must be evaluated: physical size and extent of the equipment being serviced/maintained; the relative inaccessibility of the energy isolating devices; the num ber of employees performing the servicing/maintenance; the number of energy isolating devices to be locked/tagged out; and the interdependence and interrelation ship of the components in the system or between differ ent systems. (1) Once the equipment is shut down and the hazard ous energy has been controlled, maintenance/servicing personnel, together with operations personnel, must ver ify that the isolation of the equipment is effective. The workers may walk through the affected work area to verify isolation. If there is a potential for the release or reaccumulation of hazardous energy, verification of iso lation must be continued. The servicing/maintenance workers may further verify the effectiveness of the isola S-253 21:8331 tion by the procedures that are used in doing the work (e.g., using a bleeder valve to verify depressurization, flange-breaking techniques, etc.). Throughout the main tenance and/or servicing activity, operations personnel normally maintain control of the equipment. The use of the work permit or "master tag" system (with each employee personally signing on and signing off the job to ensure continual employee accountability and control), combined with verification of hazardous energy control, work procedures, and walk through, is an acceptable approach to compliance with the group lockout/tagout and shift transfer provisions of the standard. (Note, B.l.g. of this appendix.) (2) Specific issues related to the control of hazardous energy in complex process equipment are described be low in a typical situation which could be found at any facility. This discussion is intended only as an example and is not anticipated to reflect operations at any specif ic facility, (a) Complex process equipment which is scheduled for servicing/maintenance operations is generally identified by plant supervision. Plant supervision would issue spe cific work orders regarding the operations to be performed. (b) In most instances where complex process equip ment is to be serviced or maintained, the process equip ment operators can be expected to conduct the shutdown procedure. This is generally due to their in-depth knowl edge of the equipment and the need to conduct the shutdown procedure in a safe, economic and specific sequence. (c) The operations personnel will normally prepare the equipment for lockout/tagout as they proceed and will identify the locations for blanks, blocks, etc., by placing "operations locks and/or tags'' on the equipment. The operations personnel can be expected to isolate the haz ardous energy, and drain and flush fluids from the process equipment following a standard procedure or a specific work permit procedure. (d) Upon completion of shutdown, the operations personnel would review the intended job with the servic ing and maintenance crew(s) and would ensure their full comprehension of the energy controls necessary to con duct the servicing or maintenance safely. During or immediately after the review of the job, the servicing and maintenance crews would install locks, tags and/or special isolating devices at previously identified equip ment locations following the specified work permit procedure. (e) Line openings necessary for the isolation of the equipment would normally be permitted only by special work permits issued by operations personnel. (Such line openings should be monitored by operations personnel as VVV 000006435 12-19-90 Published by THE BUREAU OF NATIONAL AFFAIRS, INC.. Washington. D.C. 20037 21 21:8332 an added safety measure.) (0 All of the previous steps should have been docu mented by a master system of accountability and re tained at the primary equipment control station for the duration of the job. The master system of accountability may manifest itself as a Master Tag which is subse quently signed by all of the maintenance/servicing work ers if they fully comprehend the details of the job and the energy isolation devices actuated or put in place. This signing by the respective workers further verifies that energy isolation training relative to this operation has been conducted. (g) After the system has been rendered safe, the authorized employees verify energy controls as described in B.3.b.(l) of this appendix. (h) Specific work functions are controlled by work permits which are issued for each shift. Each day each authorized employee assigned must sign in on the work permit at the time of arrival to the job and sign out at departure. Signature, date, and time for sign-in and signout would be recorded and retained by the applicable crew supervisor who upon completion of the permit requirements would return the permit to the operations supervisor. Work permits could extend beyond a single shift and may subsequently be the responsibility of several supervisors. (i) Upon completion of the tasks required by the work permit, the authorized employees' names can be signed off the Master Tag by their supervisor once all employ ees have signed off the work permit. The work permit is then attached to the Master Tag. (Accountability of exposed workers is maintained.) (j) As the work is completed by the various crews, the work permits and the accountability of personnel are reconciled jointly by the primary authorized employee and the operations supervisor. (k) During the progress of the work, inspection audits are conducted. (l) Upon completion of all work, the equipment is returned to the operations personnel after the mainte nance and servicing crews have removed their locks, tags, and/or special isolating devices following the com pany procedure. (m) At this time all authorized employees who were assigned to the tasks are again accounted for and veri fied to be clear from the equipment area. (n) After the completion of the servicing/maintenance work, operations personnel remove the tags originally placed to identify energy isolation. (o) Operations personnel then begin checkout, verifi cation and testing of the equipment prior to being returned to production service. REFERENCE FILE C. It should be noted that the purpose of the lockout/tagout standard is to reduce the likelihood of worker injuries and fatalities during servicing/maintenance op erations. Therefore, when compliance officers inspect workplaces, they should evaluate the potential for em ployee exposure to the unexpected release of hazardous energy during servicing/maintenance operations. When a hazard is noted, the various requirements of the standard should be applied in a manner which will result in abatement of the hazardous circumstance. OSHA INSTRUCTION CPL 2 November 13, 1990 Subject: Scope of Inspection -- Categories A. Purpose. This notice modifies OSHA policy and removes the "records only" inspection category as an inspection type. B. Scope. This notice applies OSHA-wide. C. References. 1. OSHA Instruction CPL 2.45B, June 15, 1989, Revised Field Operations Manual (FOM), Chapter II, B.5.; and Chapter III, D.l.d(4), D,7. and D.8. 2. OSHA Instruction ADM 1-1.12B, December 29, 1989, Integrated Management Information System (IMIS) Forms Manual, Chapter V, E.35. 3. OSHA Instruction CPL 2-2.38B, August 15, 1988, Inspection Procedures for the Hazard Communication Standard. 4. OSHA Instruction CPL 2-2.20B, February 5, 1990, OSHA Technical Manual (OTM). 5. OSHA Instruction STD 1-7.3, September 11, 1990, 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout) -- Inspection Procedures and Interpretive Guidance. D. Action. OSHA Regional Administrators and Na tional Office Directors shall ensure that the procedures described in this notice are implemented. These proce dures will be adopted into the FOM. E. Expiration. This notice expires October 1, 1991. F. Federal Program Change. This notice describes a Federal program change which affects State programs. Each Regional Administrator shall: 1. Ensure that a copy of this change is promptly forwarded to each State designee, using a format consist ent with the Plan Change Two-way Memorandum in Appendix P, OSHA Instruction STP 2.22A, CH-2. 2. Explain the technical content of this change to the State designee as requested. 3. Ensure that State designees are asked to acknowl edge receipt of this Federal program change in writing to the Regional Administrator as soon as the State's intention is known, but not later than 70 calendar days Wtf 000006436 Occupational Safety & Health Reporter 22