For decades, ANSI/ASSE Z244.1 and OSHA’s 29 CFR 1910.147 have stood as the industry and government standards, respectively, for the control of potentially hazardous energy. These documents share the same goal of protecting workers, but they sometimes are not aligned in the methods by which lockout/tagout safety can be achieved as technology progresses. New digital technologies are changing the way businesses operate in nearly every industry. ANSI says these new technologies may require maintenance, repair, or service work assignments where energy may need to be present to perform the job properly, which do not allow for the full application of isolation and lockout.
If an OSHA standard provides a requisite level of employee protection, OSHA says employers may not adopt an alternative approach that provides a lesser level of protection. The federal agency said this in response to a recent letter from the ANSI/ASSE Z244.1 (control of potentially hazardous energy) Accredited Standards Committee seeking clarification on lockout/tagout and the use of alternative control methods. Though, OSHA has indicated that it could update its standard in spring, as it is requesting current machinery and LO/TO data.
ANSI/ASSE Z244.1 and OSHA 29 CFR 1910.147
An alternative control methods answer was sought after ANSI took into consideration that new machining equipment and technology could continuously require power during machine maintenance. OSHA’s lockout/tagout compliance standard requires machines to be fully powerless when maintenance is being performed, which was seen as a limitation to many maintenance, repair, or service work assignments where energy may need to be present. However, in OSHA’s 1910.269 for the power generation industry, it does have rules for operating machinery that cannot be powered off.
Some industry experts have weighed in on the issue, saying that until OSHA makes changes that the best method of determining the feasibility of applying lockout or justifying dependable alternative methods to lockout are competent evaluation methods completed specific to the task being performed.
OSHA has indicated that it plans to request data and facts to possibly modernize and update its 29 CFR 1910.147 standard on hazardous energy control. The current timeline for issuance of the updated standard is April 2018. According to the American Society of Safety Engineers (ASSE), the OSHA letter substantiates the need for high-caliber training and says that the emphasis on the ANSI/ASSE Z359.2 and Z490.1 standards is significant.
“This response demonstrates that the functional protection expected by OSHA has its focus on the assured prevention of sudden start up or other release of hazardous energy that could harm workers,” said Todd Grover, global senior manager with Master Lock. Grover, who is an ANSI committee member, also said that “lockout/tagout can do this as an administrative control if the energy sources are fully understood, procedural guidance is correctly applied and sufficiently trained workers are provided the time and lockout equipment to fully control their exposure.”
To protect workers who must perform maintenance on powered machinery, follow these steps:
- Review OSHA letters of interpretation.
- Evaluate LO/TO-related programs with a focus on control of hazardous energy.
- Examine fall protection/restraint programs with an emphasis on the issue of competent/qualified person training.
- If applicable, review ANSI/ASSE standards.
- Discuss enforcement/compliance with employees.
- Reference the power generation rules found in 269 App B - Working on Exposed Energized Parts.
Control of potentially hazardous energy remains an issue of great importance to the industrial health and safety community. For the past few years, lockout is ranked as the fifth most common cause of citations among OSHA’s top 10. It had 2,877 violations in fiscal year 2017. To protect workers doing potentially hazardous work, industrial safety professionals must have a comprehensive understanding of both the ANSI/ASSE and OSHA standards and the hazards their workplace contains.
Practice Effective LO/TO Safety
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