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

Examples of Servicing and Maintenance vs. Normal Production Operations and Minor Servicing

In a printing shop, when a printing press is being used to produce printed materials, there is often the need to make minor adjustments such as to correct for paper misalignment while the press is running. This is a part of the production process, and is subject to the machine guarding requirements. The use of remote control devices which keep the employees from reaching beyond the machine guards, or the use of inch (or jog) devices that permit machine speed control for test purposesobviate the need for lockout/tagout. However, printing presses may jam, requiring an employee to bypass the machine guards in order to reach the area of the jam and clear it. Although the need to unjam the machine arises during normal production operations, it is a servicing activity that involves employee exposure to unexpected activation of the machine or release of energy, and is covered under the Lockout/Tagout standard.

In a machine shop, a milling machine operator must adjust the flow of coolant oil to parts being milled while the cutting tool is in operation. This operation, which is part of the normal production process for the machine, is covered by the machine guarding requirements, which prevent employee contact with nip points and other points of operation. However, if it becomes necessary to perform an adjustment which requires the employee to bypass a guard or to place any part of his/her body in an area where work is performed on the material or where a danger zone exists during the machine's operating cycle, the Lockout/Tagout standard applies. If this step is performed without having to bypass the guard, reach into a danger zone, or otherwise expose the employee to the potential release of energy or the unexpected activation of the machine, the Lockout/Tagout standard would not apply.

An employee is operating a machine that applies and seals a clear plastic sheet around a packaged product. There is a blade on the machine that cuts the plastic sheets, and this blade must be cleaned periodically during the production process. Since the process must be stopped to clean off the blade, that this operation is more in the nature of servicing or maintenance than normal production; on the other hand, since it must be performed frequently during production, it is arguable also part of the production process. Because the requirements of the Lockout/Tagout standard and Subpart O dovetail, protection must be provided regardless of whether the above operation is considered to be production or servicing. If it is considered by the employer to be production, the employee must be fully protected from the dangers of contacting the blade or other harmful machine parts; the cleaning must be done with special tools and procedures to provide the necessary protection. However, if it is considered to be servicing, outside of production, and the employee is exposed to a point of operation or an associated danger zone, the provisions of the Lockout/Tagout standard would apply.

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