The Control of Hazardous Energy - Enforcement Policy &

Inspection Procedures

OSHA INSTRUCTIONCPL 02-00-147

Walt Siegfried CSP, MSOffice of General

Industry Enforcement

Occupational Safety & Health

Administration

2

WHY THE MANUAL?

Paramount importance!!! Unless it’s essential, eliminate

exposure to hazardous areas Techniques to avoid exposure:

o Interview in safe locationso Photograph from a safe locationo Use engineering drawings in

lieu of direct measurement

CSHO SAFETY

WHEN IN DOUBT STAY OUT!

CPL 02-00-147 Chapter 2 Section I

3

SAFE PRACTICES

If CSHOs must inspect areas with hazardous energy exposure, they are outside personnel o Paragraph 1910.147(f)(2) applieso Do not shutdown or isolate

machineryo On-site procedure training &

communicationo Group LOTO – apply LOTO deviceo Witness verification of isolation

4

WHY A MANUAL?

Frequently cited standardso 392 Federal fatality inspections w/

1910.147 violations (10/02 – 9/07)o 3rd most cited 1910 standard

(2007)

Establish uniform inspection procedures

Consolidate energy control policy

5

HOW CAN THE MANUAL HELP YOU?

Understand how to integrate & apply hazardous energy control standards

o 1910.1471910.147 (LOTO), including the minor servicing exception

o 1910, Subpart OSubpart O (machine guarding)o 1910.332 1910.332 & 1910.3331910.333 (electrical)o Vertical LOTO provisions (such as

permit-required confined space)

6

HYDRAULIC PRESS EXAMPLE

Hazardous energy control steps may involve…

Lockout (safety blocks, disconnect switch, hydraulic valve),

Safeguarding (2-hand control), and/or

Electrical safe work practices (by a qualified electrical person)

…depending on the servicing/maintenance task.

7

SUPPLEMENTAL ASPECT

1910.147 procedure & training provisions supplement other vertical LOTO standards to the extent that they are not regulated by the specific LOTO provision

Some other standards that have LOTO requirements:o 1910.146 - Permit-required confined spaceso 1910.179 - Craneso 1910.217 - Mechanical power presseso 1910.268 - Telecommunicationso 1910.272 - Grain handling

8

HOW CAN IT HELP?

Links key interpretations/legal decisionso Addresses enforcement strategies - e.g., unexpected

energization or startup Multi-employer policy scenarios

o IBP, Inc. Court of Appeals decision – consult SOL Affirmative defense scenarios

o Unpreventable employee misconduct and isolated instance; foreman misconduct; greater hazard; impossibility

Citation examples

CPL 02-00-147 Chapter 3 Section I

9

KEY DEFINITIONS

Hazardous Energy - Energy that could cause injury to employees

Servicing and/or Maintenance - Timken Company OSHRC decision note

o Equipment that functions separately is not part of the same equipment

CPL 02-00-147 Chapter 1 Section IX p. 1-14

10

KEY DEFINITIONS (cont.)

Authorized Employee: Employee who performs equipment service/maintenance or implements these procedures, including:

Performing energy isolation Implementing LOTO on equipment Dissipating stored energy Verifying isolation Implementing actions to release LOTO Testing or positioning equipment components

11

POLICY ISSUES

Scope & application Energy control programs

o Tagout programs Specific procedures Periodic inspections Group LOTO Vehicles Alternatives

12

SCOPE & APPLICATION

Normal production operations: Utilization of equipment to perform its intended production function o Usually covered by

Subpart O 1910.147 covers the control of

energy during machine servicing/maintenance where injury may resulto Both potential & kinetic

energy

CPL 02-00-147 Chapter 3 Section II p. 3-2

13

ENERGY CONTROL PROCEDURES

Control procedures must provide:

Sufficient detail and Specific guidance for the

energy control steps so that authorized employees clearly understand how to safely utilize control measures for the machine being serviced/maintained.

ABC Co.Energy Control Procedure

Purpose

______________________________________________________________________________

Compliance with this program ______________________________________________________________________________

Sequence of Lockout

(1)__________________________________________________

CPL 02-00-147 Chapter 3 Section IX p. 3-39

14

SPECIFIC PROCEDURES

OSHA retained the word specific in the final rule because overgeneralization does not provide employees with sufficient information to effectively control hazardous energy.

Generic procedures alone are unacceptable

Work permits, checklists, placards may be used to supplement generic procedures

15

PROCEDURE GROUPING

Similar machines/equipment may be grouped if they are listed in the procedure scope & all have the same or similar control steps to: Shut down, isolate, block, secure & dissipate stored

energy Place, remove & transfer LOTO devices &

responsibility for them Test a machine/equipment to determine & verify

effectiveness of control measures

16

PERIODIC INSPECTION COMPONENTS

Periodic inspection of each procedure (annually) Review employee responsibilities – Observe &

interview Authorized employees for LO Authorized & affected employees for TO

Purpose is to verify Procedure steps are followed Employees know their responsibilities Procedure is adequate

CPL 02-00-147 Chapter 3 Section XVII p. 3-65

17

STREAMLINED PROCESS

Inspect a representative # of employees implementing the procedure

Perform supplemental review with remainder of employeeso Used for same or similar machines/equipment

that have same or similar control measureso Reviews may be performed by group meetings

This approach is acceptable if the inspection sampling reasonably reflects hazardous energy control practices.

18

Personal Lockout -Tagout Devices

Satellite Lockbox/Tagbox

Group LockoutTagout Mechanism

Master Lockbox/Tagbox

EquipmentLockout-Tagout

AE

C

F

G H

B

P1

D

P2

CrewLeader

D

CG

A

Exchanger

P1

P1

P2

P2

B F

E

H

Personal Lockout -Tagout Devices

Satellite Lockbox/Tagbox

Group LockoutTagout Mechanism

Master Lockbox/Tagbox

EquipmentLockout-Tagout

AE

C

F

G H

B

P1

D

P2

AE

C

F

G H

B

P1

D

P2

AE

C

F

G H

B

P1

D

P2

CrewLeader

D

CG

A

Exchanger

P1

P1

P2

P2

B F

E

H D

CG

A

Exchanger

P1

P1

P2

P2

B F

E

H

TYPE C

GROUP LOCKOUT / TAGOUT

CPL 02-00-147 Chapter 4

19

VEHICLE HAZARDOUS ENERGY CONTROL

Vehicle servicing and maintenance activities have caused serious injury & death

1910.147 applies to general industry workplaces that service or maintain vehicles; such as: Automobiles Trucks Tractors Transport vehicles Material handling equipment

CPL 02-00-147 Chapter 3 Section III p. 3-22

20

PROGRAM FLEXIBILITY

An energy control program is necessary; however, due to nature & unique aspect of vehicle maintenance, the energy control measures must be tailored to the workplace. For example, sole control of ignition key

may provide protection in some, but not all, situations.

21

LOTO ALTERNATIVES

Machine guarding Cord & plug-

connected equipment

Control circuitry (variances)

Other abatement methods

CPL 02-00-147 Chapter 2 Section IV p. 2-15

22

MINOR SERVICING EXCEPTION

Limited exception! Work is minor in nature Routine & repetitive Performed during normal production

operations Integral to the use of the equipment

for production Work is performed using alternative

methods which provide effective protection

CPL 02-00-147 Chapter 3 Section IV p. 3-25

23

LEGAL DECISIONS

Westvaco Corporationo Work performed before the normal production

operation (NPO) is not covered by the MSEo Setting up prepares a machine to perform its NPO

and, by definition, does not occur during NPO

Falcon Steel Co. o Party claiming benefit of exception has burden

of proving scenario falls within exceptiono Document specific inadequacies (e.g. injuries)

with 1 or more MSE elements – i.e., to refute an employer’s claim that 1910.147 does not apply because of the exception

24

HOW CAN YOU USE THE MANUAL?

Protect yourself - CSHO safety practices

Apply enforcement policy & procedures Compliment other directives - e.g.,

amputation NEP, slide lock directive, die-set directive

Link to case law, interpretation letters, CSB & NIOSH incident reports

Locate references (Chapter 5) Education & training purposes

25

LEGAL SUFFICIENCY

Prima Facie Cited standard is applicable Employer failed to comply Employees were exposed Employer knowledge

Apply Enforcement flow diagrams Multi-employer policy Legal decision strategies

Refute Affirmative defenses Minor servicing exception

Building anOSHA 1B Form

26

SUMMARY

Always protect yourself Use the Manual as a resource Understand: that energy

control standards are interrelated and how to apply them

Use the policy to establish violations that meet the legally sufficiency test