Suppose an OSHA inspector asks you to provide the names of the affected employees for the lockout/tagout procedure used on a specific date (for example, three weeks ago) for Asset 91-865 (a scrap grinder). Would you know who those people are? What if the same OSHA inspector asks you to provide the names of the authorized employees for the same procedure used on the same date for the same equipment? Would this be confusing?
Not if you are familiar with the 14 definitions in 29CFR 1910.147(b). An “affected” employee is one whose job requires him/her to:
- Operate (or use) a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or
- Work in an area where such servicing or maintenance is being performed.
This might be an unclear definition. What does OSHA meant by “area?” Is that 6 ft from the scrap grinder or is that the end of the plant where the scrap grinders are located? If an operator is assisting the maintenance people by jogging the drive motor, the operator is an “affected” employee. But if the same operator is pulling poorly extruded parts off the end of the production line and tossing them into a bin which will later be moved 15 ft over to the grinder, is that an “affected” employee?
The key to understanding what is meant is in the purpose as stated in 29CFR 1910.147(a), which is “to protect the employee.” So now you can see that “area” means a space in which employees might be exposed to danger from the equipment under question.
An “affected” employee becomes an “authorized” employee when that person’s duties include performing the servicing or maintenance covered by 29CFR 1910.147. This is the person who locks out or tags out machines or equipment to perform those duties.
Some other terms can be baffling, unless you view them through the lens of the purpose stated in 29CFR 1910.147(a). For example, “Energized” means connected to an energy source or containing residual or stored energy.”
To an electrician whose work has always involved working on electrical circuits but not on the utilization equipment, this term would mean electrical energy. Lock out the circuit disconnecting device, and the equipment isn’t energized — except it very well might be energized.
It could be, for example, the kinetic energy stored in an industrial press whose ram is sitting at the half-stroke position. It could be chemical, as in the energy stored in a battery. Mechanical springs store energy. Energy is stored thermally, and residual heat can be lethal many hours after the heat source itself is de-energized (e.g., in a kiln). It’s not about whether electrical circuits are energized, but whether enough energy is present in some form to endanger an employee.
There are lockout devices, and there are tagout devices. A lockout device physically prevents the device from being operated. A tagout device instructs people not to operate the device. The lockout device has a means of identifying who hung the lock, per 29CFR 1910.147(c)(5)(D). OSHA gives the employer leeway on this, and we will look more closely at it in a future installment. The tagout device has this same ID requirement.
Companies wishing to avoid OSHA citations for their LOTO program must ensure that anyone involved in developing, training, or administering their LOTO program doesn’t just gloss over 29CFR 1910.147(a) and (b) to “get to the meat of it.” If they do, that meat will be tough to chew and they will choke on it.
