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May 22, 2019
OSHA seeks input on lockout/tagout

The Occupational Safety and Health Administration (OSHA) is asking for comments, data, and information about possible revisions to its Control of Hazardous Energy (Lockout/Tagout) standard. The agency is considering whether to accept alternatives to energy-isolating devices.

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OSHA is contemplating two changes to the standard:

  • Allowing the use of control circuit type devices for the control of hazardous energy, while equipment or machines are being maintained or serviced; and
  • Amending the general industry standard to address hazardous energy control for new robotics technologies.

The request for information makes no mention of reinstating the agency’s Oct. 4, 2016 proposal to remove the word “unexpected” from the application of the standard.

Recognizing technological advances

OSHA wants to know whether control circuit type devices can protect workers as effectively as lockout/tagout energy-isolating devices. The existing standard excludes push buttons, selector switches, and other control circuit type devices. The agency now is acknowledging the technology has improved since it first established the standard in 1989.

OSHA April 8, 2016, granted a permanent variance to Nucor Steel Connecticut Inc., permitting the use of a control circuit type device for the control of hazardous energy under specific conditions. Nucor’s variance involves a “trapped key” system, where the employee maintaining the machine has possession of the only key that can restart it.

After determining the proposed system was an effective alternative to a full lockout, OSHA decided that there may be a basis for amending the standard.

Questions for stakeholders

The agency is looking for detailed answers to several questions. OSHA’s questions include:

  • What are the limitations of control circuit type devices and when would they be appropriate to use and when would they be inadvisable;
  • If OSHA allows the use of control circuit type devices for hazardous energy control, would employers choose to use them;
  • How do new control circuit type devices address the agency’s initial concerns they could fail due to component failure, electrical surges, magnetic field interference, or improper use or maintenance;
  • Would allowing their use save employers money or simplify operations or maintenance;
  • How would the use of control circuit type devices affect employee training – would more training be required for new employees or would it take longer; and
  • Should OSHA incorporate elements of the current consensus standard for the control of hazardous energy, ANSI Z244.1?

Human-robot interaction

The use of robotics in industry has changed. The traditional robot model involved a large device that had a fixed base and workers stayed behind a locked door or in a locked compartment while it operated. During maintenance the robot’s movements were limited or greatly slowed.

Workers now use collaborative robots, including some units that function as an exoskeleton worn by a worker.

OSHA wants to know if its standard needs to be updated to address risks of hazardous energy that workers may face in the increased interaction with robots and is seeking stakeholder input.

OSHA also wants to know about the following:

  • Any instances of worker deaths or injuries caused by the release of hazardous energy while working with robotics technology;
  • Whether the agency should revise the lockout/tagout standard to cover software to ensure the safe operation of robots;
  • Whether employers are currently using lockout/tagout method to control hazardous energy in robots; and
  • Whether the agency should adopt portions of consensus standards for industrial robots.

OSHA also wants to hear from stakeholders about the potential economic impacts of any revisions to the lockout/tagout standard especially those that apply to small employers.

No mention of “unexpected”

When OSHA recently finalized the fourth phase of the Standards Improvement Project (SIP), the rule did not include a proposed change to remove “unexpected” from the lockout/tagout standard as previous drafts of the SIP had.

The agency had sought the change because it believes the Occupational Safety and Health Review Commission and federal courts misunderstand the regulation’s purpose. Employers objected to the change proposed in 2016, stating that removing the single word broadened the scope of the standard.
The latest SIP doesn’t address this issue.

Comments on the request for information (RFI) on energy-isolating devices are due August 19.

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