Lockout/tagout procedures are core pieces of any industrial company's safety protocols. The release of energy as a machine is powered on accidentally can be fatal: The U.S. Occupational Safety and Hazard Administration says lockout/tagout procedures prevent 120 deaths and 50,000 injuries a year. Given the importance of these processes, businesses need to be aware of lockout/tagout changes OSHA has proposed that may affect your own workplace training and compliance.
Why one word matters so much
Although OSHA put forth a raft of changes – 18 in all – in October 2016 aimed at revising standards, according to AutomationWorld, it was the change to Control of Hazardous Energy Standard (29 C.F.R. part 1910.147) that garnered the most attention from industrial employers and stakeholders. The rule sets guidelines for protecting workers when "the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees."
"New lockout/tagout procedures, if approved, would apply to more machines than many companies are currently prepared to meet compliance for."
Under the change OSHA submitted to public comment, "unexpected" would be removed. The safety agency argues it wants to clarify its original intent to mean "unexpected energization" as all re-energization startups before lockout/tagout devices are removed, not just when the release of stored energy by a machine would be "unexpected."
This seemingly small semantic change could have large repercussions for employers. If approved, lockout/tagout procedures, which require a full shutdown, would have to be applied to more machines than factory floors or processing plants are currently prepared to meet compliance for.
Court case can provide insight
In a series of judgments issued in favor of GMC in the late '90s, lockout/tagout was ruled to not cover maintenance activity on machines that had proper advance warning functions and where the only risk being a startup while an employee is in a danger zone — an unexpected reenergization. As BNA Bloomberg reported, industry stakeholders have cautioned the revised rule could burden employers by having to divert more resources toward overhauling current lockout/tagout procedures that comply according to the law, even if they don't rely solely on these setups.
Looking ahead for lockout/tagout
Compliance with OSHA lockout/tagout mandates is difficult for many employers. As a way to better improve their internal procedures, companies can look to the ANSI/ASSE Z244.1 as a model for modern approaches to lockout/tagout responsibilities. Developed with scalability in mind, rather than the zero-risk blanket approach, the best practices included in the standard allow for right-sizing changes to lockout/tagout procedures.
Remember, ANSI/ASSE Z244.1 is guidance, not the law, and OSHA will dictate enforcement policies. However, coupling best practices that bring lockout/tagout procedures in step with where compliance is trending can set companies up to keep workers safe and ensure adherence to the rules in the future.