Relationship of 1910.147, The Control of Hazardous Energy (Lockout/Tagout) Standard, to Subpart O, Machinery and Machine Guarding Standards

Some servicing operations performed during normal production operations are excepted from coverage under the Lockout/Tagout standard. This exception is referred to as the minor servicing exception. The Lockout/Tagout standard is not intended to cover minor servicing activities that are necessary to carry out the production process provided that associated danger zones are properly guarded. The machine guarding standards in Subpart O cover these types of operations.

The Lockout/Tagout standard contains specific criteria that must be met for the minor servicing exception to apply. Minor tool changes and adjustments,and other minor servicing activities that take place during normal production operations, are not covered by the standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection.

If the servicing operation is routine, repetitive, and must be performed as part of the production process, the employer must use alternative protective methods or safeguarding devices (such as remote oilers and specially designed servicing tools), to protect employees.

Three specific criteria can be used to determine if the minor servicing exception would apply to a particular activity.

First, the activity must be conducted during normal production operations, i.e., while the machine or equipment is actually performing its intended production function.

Second, the activity must be:

• Routine: The activity must be a regular course of procedure and be in accordance with established practices.

• Repetitive: The activity must be regularly repeated as part of the production process.

• Integral: The activity must be essential to the production process.

Third, if all of these apply, the employer must use alternative measures to provide effective protection from the hazardous energy. Some acceptable alternative measures include specially designed tools, remote devices, interlocked barrier guards, local disconnects, or control switches which are under the exclusive control of the employer performing the minor servicing. These alternative measures must enable the employee to safely perform the servicing task without being exposed to the unexpected energization or activation of the equipment, or the release of stored energy.

If the minor servicing exception is not met in full, the Lockout/Tagout standard is applicable and the machine or equipment must be deenergized and all potentially hazardous energy rendered safe.

The preamble provides further clarification for routine, repetitive, and integral to the use of equipment for production.

Also, refer to directive STD 1-7.3, Appendix C, paragraph A, [Note: You will need to scroll down to Appendix C, paragraph A in the directive.] for more information regarding alternative measures that may be used to comply with the Lockout/Tagout standard.

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