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 Selection and Use of Electrical Work Practices Standard

The Lockout/Tagout standard, 1910.147 does not cover exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations, which is covered by Subpart S. OSHA Subpart S is intended to cover safety requirements that are necessary for the practical safeguarding of employees. It does not cover other equipment-related hazards that do not involve exposed electrical parts.

The requirements contained within the Lockout/Tagout standard for deenergizing machines and equipment are similar to the requirements for Selection and Use of Electrical Work Practices standard, 1910.333. The Selection and Use of Electrical Work Practices standard covers work on or near exposed, deenergized electrical parts and includes the necessary requirements for lockout and tagging of the means of disconnecting equipment. However, the standard does not address a mechanic servicing the mechanical parts of an electrically-powered machine, which is covered under the Lockout/Tagout standard.

Energy Control Programs for the Lockout/Tagout and Use of Electrical Work Practices Standard

Both paragraph (c)(1) of the Lockout/Tagout standard and paragraph (b)(2) of the Selection and Use of Electrical Work Practices standard require the employer to develop energy control procedures. As specified in Note 2 to (b)(2) of the Selection and Use of Electrical Work Practices standard, it would be acceptable for an employer to develop energy control procedures in accordance with the Lockout/Tagout standard to fulfill the requirements of section (b)(2) of the Selection and Use of Electrical Work Practices standard. As further specified in Note 2, however, the employer's procedures must also meet the requirements in paragraphs (b)(2)(iii)(D) and (b)(2)(iv)(B) of the Selection and Use of Electrical Work Practices standard. This enables an employer to use a single lockout and tagout program to cover all hazards addressed by both these standards, as long as the program includes procedures that meet the two additional paragraphs when exposure to electric shock is involved.

In comparing proposed 1910.333(b)(2) with final 1910.147. OSHA determined that the new generic lockout standard encompassed all the lockout and tagging requirements contained in the electrical work practices proposal with two exceptions. First, the proposed electrical standard more tightly restricted the use of tags without locks and called for additional protection when tags were permitted. Secondly, the electrical work practices proposal contained specific requirements for testing circuit parts for voltage before they could be considered as deenergized. OSHA believes that a lockout and tagging program which meets 1910.147, will, with these two exceptions provide protection for servicing and maintenance involving electrical work and live parts. Accordingly, the final rule on electrical safety-related work practices incorporates this finding. OSHA has decided to accept, by means of a note added to final 1910.333(b)(2), any lockout and tagging program that conforms to 1910.147 if it also meets paragraphs (b)(2)(iii)(D) and (b)(2)(iv)(B) of final 1910.333. This will enable employers to use a single lockout and tagout program to cover all hazards addressed by these two standards, as long as that program includes procedures that meet the two additional paragraphs when exposure to electric shock is involved.

For additional information, refer to OSHA Directive STD 1-16.7, and the Preamble to the Lockout/Tagout standard, 1910.147.

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