Normal Production Operations - Lockout/Tagout
Machines and equipment present many hazardous situations during normal production operations — i.e., whenever machines and equipment are used to perform their usual production function. These production hazards are covered by other rules, such as the requirements for general machine guarding and guarding power transmission apparatus. In certain circumstances, such as the following examples, some servicing or maintenance hazards encountered during normal production operations may be covered by the lockout/tagout rule.
If a servicing activity — such as lubricating, cleaning, or unjamming the production equipment — takes place during production, the employee performing the servicing may be subjected to hazards that are not encountered as part of the production operation itself. Workers engaged in these operations are covered by lockout/tagout when any of the following conditions occur:
§ The employee must either remove or bypass machine guards or other safety devices, resulting in exposure to hazards at the point of operation;
§ The employee is required to place any part of his or her body in contact with the point of operation of the operational machine or piece of equipment; or
§ The employee is required to place any part of his or her body into a danger zone associated with a machine operating cycle.
In these situations, the equipment must be deenergized and locks or tags must be applied to the energy-isolation devices. In addition, when other servicing tasks occur, such as setting up equipment, and/or making significant adjustments to machines, employees performing the tasks are required to lock out or tag out if they can be injured by unexpected energization or startup of the equipment.
Some servicing operations must be performed with the power on. Making many types of fine adjustments, such as centering the belt on conveyors, is one example. Certain aspects of troubleshooting, such as identifying the source of the problem as well as checking to ensure that it has been corrected, is another. You must provide effective protection when employees perform such operations. Although, in these cases, a power-on condition is essential either to accomplish the partitular type of servicing or to verify that it was performed properly, lockout or tagout procedures are required when other service or maintenance occurs and power is not required.
Employees performing minor tool changes and adjustments and/or other minor servicing activities that are routine, repetitive, and integral to the use of the production equipment and that occur during normal production operations are not covered by the lockout/tagout standard, provided the work is performed using alternative measures that provide effective protection.
In an interpretative letter dated July 23, 1992 OSHA clarified how the Lockout/Tagout standard would apply to motor vehicles.
"Specifically, you posed the following question: If a truck driver or other person were to crawl under a truck, with the engine running, to adjust a linkage or fix another problem, would this be considered a violation of the standard?
The answer is: Yes, this would constitute a hazard, as well as a violation. We would agree with the verbal opinion offered by Mr. Sauger that turning the engine off and removing the ignition key would deenergize and isolate the power source. The key would also have to be retained by the employee performing the maintenance operation in order to provide effective protection under the standard.
When servicing or maintenance activities are to take place, on any equipment, deenergization of that equipment will provide maximum safety to an employee. The removal of a vehicle key which can be kept in the sole control of the employee performing the maintenance or service can significantly reduce the risk of serious injury or even possibly a fatal injury."
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