Letter: Lockout/tagout exception ‘not as simple as it appears’

I wish to comment on an article published in the June 2018 edition of Safety+Health entitled, Alternative measures for lockout/tagout, that was in the “Workplace Solutions” section.

I would also like to preface my comments with an acknowledgement that 1910.147 does, in fact, provide for an exception to lockout/tagout during normal production operations. However, in actual practice, that exception is frequently misapplied. The exception is not as simple as it appears, and the actual application in the work environment is very complicated. As a matter of fact, I believe that all exceptions should be reviewed and approved by a seasoned safety professional with extensive knowledge and experience.

The writer suggests that the “minor servicing exception” is “designed for machine tasks that demand frequent repetitive access (e.g., clearing a jam ...”). It must be pointed out that clearing a jam is, by definition, servicing and maintenance.

1910.147(b): Servicing and/or maintenance. Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.

While I feel confident that the writer understands the exception and would be capable of proper implementation, I do not think that this is the case with most readers. Unfortunately, my experience tells me that production operators and inexperienced safety officers will think that clearing all jams is an exception to lockout/tagout.

Another misinterpretation of the “exception” involves the term “normal production operations.” A normal production operation is defined as using a machine or equipment to perform its intended production function. As soon as a machine or equipment is shut down, production stops and service and maintenance begin. (See the preamble to 1910.147.) Lockout/tagout is required for service and maintenance. The exception only applies during normal production operations.

Ron McHaney, CSP
Spokane, WA