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Relationship of 1910.147, The Control of Hazardous Energy (Lockout/Tagout) Standard, to 1910.269, Electric Power Generation, Transmission, and Distribution Standard, and 1910.333, Selection and Use of Electrical Work Practices Standard

Lockout/Tagout and Electric Power Generation, Transmission, and Distribution Standard

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The Lockout/Tagout standard does not cover installations under the exclusive control of electric utilities for the purpose of power generation, transmission, and distribution, including related equipment for communication or metering; these would be covered by the Electric Power Generation, Transmission, and Distribution standard, 1910.269.

Paragraphs (d) and (m) of the Electric Power Generation, Transmission, and Distribution standard specify the control of electrical energy requirements that apply to operations and maintenance work. The lockout/tagout procedures of 1910.269(d) apply to the control of electrical energy in installations for the purpose of electric power generation, including related equipment for communication or metering. The locking and tagging procedures of 1910.269(m) apply to deenergizing of electric energy sources that are used exclusively for purposes of transmission and distribution.

Paragraph (d)(1) of 1910.269 notes that installations in electric power generation facilities that are not an integral part of, or inextricably commingled with, power generation processes or equipment are covered under the Control of Hazardous Energy standard and Subpart S.

Energy Control Programs for the Lockout/Tagout and Electric Power Generation, Transmission, and Distribution Standard

Paragraph (d)(1) of the Electrical Power Generation, Transmission, and Distribution standard limits the application to energy sources in installations for the purpose of electric power generation, including related equipment for communication or metering. The scope of this paragraph of the standard is intended to coincide with the exemption from the Lockout/Tagout standard (described in 1910.147(a)(1)(ii)(B). Electrical installations in electric generating plants that are not addressed in 1910.269(d) are covered in Subpart S of Part 1910.

Note: The existing electrical regulations contained in Subpart S, including the Electrical Safety-Related Work Practices lockout and tagging requirements, address electrical utilization systems (e.g., installations of electrical conductors and equipment which uses electric energy for mechanical, chemical, heating, lighting, or similar purposes). Subpart S protects most employees from the hazards associated with electrical utilization equipment and with the premises wiring that supplies this equipment.

This scope description coincides with the electrical utilization system exemption provisions of 1910.147(a)(1)(ii)(B). OSHA Instructions CPL 2-1.18A (on the Electrical Power Generation, Transmission, and Distribution standard), STD 1-7.3 (on the Control of Hazardous Energy standard), and STD 1-16.7 (on the Electrical Safety-Related Work Practices standard) should be consulted for compliance policy and guidance purposes.

Hazardous energy control procedures in 1910.269(d), with the exception of (d)(8)(v),(dealing with centrally located control facilities), are taken nearly verbatim from 1910.147. Both section 1910.147(c) of the Lockout/Tagout standard and 1910.269(d) of the Electric Power Generation, Transmission, and Distribution standard require the employer to develop an energy control program consisting of energy control procedures, employee training, and periodic inspections. An energy control program that complies with the requirements of the Lockout/Tagout standard would also meet the requirements of 1910.269(d)(2)(ii), as long as the program addresses the hazards covered by paragraph (d) of the Electric Power Generation, Transmission, and Distribution standard.

Paragraph (m) of the Electric Power Generation, Transmission, and Distribution standard specifies procedures for the deenergization of electrical energy sources used exclusively for purposes of transmission or distribution. Implementing the procedures under the Lockout/Tagout standard, 1910.147 does not fulfill the requirements for implementing energy control procedures under paragraph (m) of the Electric Power Generation, Transmission, and Distribution standard when deenergizing electrical energy sources used for transmission or distribution. Refer to OSHA Directive CPL 2-1.18A for additional information.

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