29 CFR Sub Part J 1910 147 The

29 CFR Sub. Part J 1910. 147 The control of hazardous energy (lockout/tagout). 1

1910. 147 The control of hazardous energy (lockout/tagout) My presentation will not cover all requirements of the standard. 2

1910. 147(a)(1) Scope (i) This 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. 3

1910. 147(a)(2) Application (ii) Servicing and/or maintenance which takes place during normal production operations is covered by this standard only if: – (A) An employee is required to remove or bypass a guard or other safety device; or – (B) An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle. When LOTO applies 4

1910. 147(a)(1) Scope (ii) This standard does not cover: ― Construction and agriculture ― Maritime (Parts 1915, 1917, & 1918) ― Installations under exclusive control of electric utilities (1910. 269) ― Electrical hazards from work on, near, or with conductors or equipment in electric-utilization installations covered by subpart S (1910. 301 – 1910. 399) ― Oil and gas well drilling and servicing 5

1910. 147(a)(2) Application (iii) This standard does not apply to - Work on cord and plug provided the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance. - Hot tap operations 6

1910. 147 Definitions (b) Affected employee Lockout device Tagout device Energized Authorized employee Energy isolating device Capable of being locked out Hot tap Energy source Tagout Normal production operations Lockout Setting up 7 Servicing and/or maintenance

1910. 147(b) Definitions “Energy source" Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. “Servicing and/or maintenance" Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy. 8

1910. 147(b) Definitions "Affected employee" An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed. "Authorized employee" A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section. Lockout or tagout is used by these employees for their protection. 9

1910. 147(c) "General" (1) Energy control program establishes: – Energy control procedures – Employee training – Periodic inspections to ensure that machine or equipment shall be isolated from the energy source and rendered inoperative 10

1910. 147(c)(4)(i) "Energy control procedure" Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. 11

1910. 147(c)(4)(i) "Energy control procedure" Documented Procedure Exception – Machine/equipment has no potential for stored, residual, or reaccumulation of energy after shut down – Machine/equipment has a single energy source readily identified and isolated – The isolation and locking out of the energy source will completely deenergize/deactivate the machine/equipment – Machine/equipment is isolated from the energy source and locked out during servicing or maintenance 12

1910. 147(c)(4)(i) "Energy control procedure" Documented Procedure Exception (continued) – Single lockout device will achieve a locked out condition – Lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance – Servicing/maintenance does not create hazards for other employees; and – Employer has had no accidents involving the unexpected activation or reenergization of the machine/equipment during servicing or maintenance 13

1910. 147(c)(4)(ii) "Energy control procedure" The procedures shall clearly and specifically outline the: – Scope, purpose, authorization, rules, – Techniques to be utilized for the control of hazardous energy, – Means to enforce compliance – A specific statement of the intended use of the procedure; – Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy 14

1910. 147(c)(4)(ii) "Energy control procedure" Procedures outline (continued): – Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and – Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures. 15

1910. 147(c)(5) "Protective materials and hardware" (i) Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware shall be provided by the employer for isolating, securing or blocking of machines or equipment from energy sources. (ii) Lockout devices and tagout devices shall be singularly identified; shall be the only device(s) used for controlling energy; shall not be used for other purposes; … 16

1910. 147(c)(6) "Periodic inspection" (i) The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed. ic n d io tio r Pe pec Ins 17

1910. 147(c)(6) "Periodic inspection" (A) Performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected. (B) Conducted to correct any deviations or inadequacies identified. (C) LOCKOUT - Review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected. (D) TAGOUT - Include a review, between the inspector and each authorized and affected employee, of that employee's responsibilities under the energy control procedure being inspected. (DOE Inspector General Report OAI -L-16 -08 dated March 2016) Periodic Inspections 18

Response Line Record ID # D 98 -02 -021 QUESTION 29 CFR 1910. 147(c)(6)(C), Periodic Inspections states, "the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected. “ 1. Please provide clarification regarding the intent of "each" authorized employee, and the "procedure being inspected. " The concern from our operations management is that we have several hundred authorized employees performing LO/TO activities. Is it OSHA's intent to perform a review of a specific LO/TO detailed work activity and interview the authorized employees performing the specific LO/TO work activity? 2. I am assuming that the facility LO/TO implementing procedure is not the procedure referenced above in the OSHA citation. I am attaching an example of a Tagout Authorization form (TAF) used for a specific LO/TO work activity. Is this what OSHA is calling "the procedure being inspected? “ 3. How large a sample is customarily regarded as appropriate for performing 19 the annual periodic inspection?

Response Line Record ID # D 98 -02 -021 Regulatory Review 1. It is the intent of the LO/TO standard, 29 CFR 1910. 147 that all authorized employees, as defined by 1910. 147(b), be reviewed by an inspector designated by the employer during the course of the year to insure that the employee is knowledgeable of the LO/TO procedure or procedures, and properly implements these procedures. This verification can be done with any combination of observation, training (classroom or on the job), interview and written examination. (1910. 147(c)(7)) 20

Response Line Record ID # D 98 -02 -021 Regulatory Review (continued) 2. The LO/TO implementing procedure referenced in the standard is the procedure that the employee is expected to use. When the employee is expected to use more than one procedure, then a review of these multiple procedures would be required. 21

Response Line Record ID # D 98 -02 -021 Regulatory Review (continued) 3. All authorized employees must be reviewed by an inspector on a periodic basis, as stated in 1910. 147(c)(6)(i)(C). Not all employees must be observed, but to quote the OSHA STD 1 -7. 3, "29 CFR 1910. 147, the Control of Hazardous (Lockout/Tagout) - Inspection Procedures and Interpretive Guidance": "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 intended 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)). " 29 CFR 1910. 147 is a performance standard and does not stipulate the number of audits or visual observations. It is for the employer to decide how best to implement its LO/TO program and its inspection criteria program. Note - OSHA STD 1 -7. 3 was cancelled by OSHA CPL 02 -00 -147 22

1910. 147(c)(6) "Periodic inspection" Preamble - The inspector who is required to be an authorized person not involved in the energy control procedure being inspected, must be able to determine three things; - Whether the steps in the energy control procedure are being followed; - Whether the authorized (and affected – tagout only) involved know their responsibilities under the procedure; and - Whether the procedure is adequate to provide the necessary protection, and what changes, if any, are needed. 23

1910. 147(c)(6) "Periodic inspection“ 1910. 147(c)(6)(ii) The employer shall certify that the periodic inspections have been performed. – Identify the machine or equipment on which the energy control procedure was being utilized, – Date of the inspection – Employees included in the inspection – Person performing the inspection. Certify Periodic Inspection 24

1910. 147(c)(7) "Training and communication" (i) The employer shall - Provide training on the purpose and function of the energy control program - Ensure that the training is understood - Ensure that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired 25

1910. 147(c)(7) "Training and communication" (A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control. (B) Each affected employee shall be instructed in the purpose and use of the energy control procedure. (C) All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out. Affected Authorized 26

1910. 147(c)(7) "Training and communication" (ii) When tagout systems are used, employees shall also be trained on the limitations of the tags. 27

1910. 147(c)(7) "Training and communication" (iii) Employee retraining (A) Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures. (B) Additional retraining shall also be conducted whenever a periodic inspection under paragraph (c)(6) of this section reveals, or whenever the employer has reason to believe that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures. (C) The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary. 28

1910. 147(c)(7) "Training and communication" (iv) The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee's name and dates of training. Certify Periodic Inspection 29

1910. 147(c)(9) “Notification of employees" Notification of employees. Affected employees shall be notified by the employer or authorized employee of the application and removal of lockout devices or tagout devices. Notification shall be given before the controls are applied, and after they are removed from the machine or equipment. Affected Authorized 30

Tomorrow – your reward for working safely today. ~Author Unknown 31

1910. 333(b) “Working on or near deenergized parts” 1910. 333(b)(2) "Lockout and Tagging. " While any employee is exposed to contact with parts of fixed electric equipment or circuits which have been deenergized, the circuits energizing the parts shall be locked out or tagged or both in accordance with the requirements of this paragraph. The requirements shall be followed in the order in which they are presented (i. e. , paragraph (b)(2)(i) first, then paragraph (b)(2)(ii), etc. ). Note 2: Lockout and tagging procedures that comply with paragraphs (c) through (f) of 1910. 147 will also be deemed to comply with paragraph (b)(2) of this section provided that: [1] The procedures address the electrical safety hazards covered by this Subpart; and [2] The procedures also incorporate the requirements of paragraphs (b)(2)(iii)[D] (a tag used without a lock) and (b)(2)(iv)[B] (zero energy check) of this section. 32