OSHA
[ Tutorial ]
[ Hot Topics ]
[ Case Studies ]
[ LOTO standard ]
[ LOTO preamble ]
[ Compliance directive ]
[ Selected case law ]
[ Selected letters of interpretation ]
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
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.
Next Page>>
| Topic Contents
|