OSHA provides the requirements for the control of hazardous energy in 29CFR.1910.147. The general requirements [1910.147(C)] are extensive. Let’s look at the first three, beginning with the energy control program.
The employer must establish a program that consists of:
- Energy control procedures
- Employee training
- Periodic inspections.
The reason for this program and those three elements in particular is to ensure that, before any employee performs any servicing on any equipment where startup or the release of stored energy could occur and could cause injury, that equipment is isolated from the energy source(s) and rendered inoperative [29CFR.1910.147(c)(1)].
The second general requirement is for lockout/tagout (LOTO). OSHA wants the equipment locked out. If it can be locked out, you should lock it out [29CFR.1910.147(c)(2)(2)]. But sometimes, this isn’t feasible or possible. So OSHA will permit it to be just tagged out [29CFR.1910.147(c)(2)(1)]. But the feasibility part has to be accounted for, so OSHA goes on to say that if the employer can demonstrate that using the tagout system will provide full employee protection then that is permitted.
The third general requirement is “full employee protection.” You can see why it follows the second requirement. It requires the tagout device to be attached at the same location a locking device would have been attached if the equipment is capable of being locked out [29CFR.1910.147(c)(3)(1)]. Reiterated here is the demonstration requirement stated in [29CFR.1910.147(c)(2)].
But then it goes on to also require the employer to demonstrate full compliance with all tagout-related provisions within 29CFR.1910.147. And it states that additional means to be considered as part of the demonstration “…shall include the implementation of an isolating circuit element, blocking of a control switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.” In other words, OSHA doesn’t trust the tag to do the job on its own — and neither should you.
A practical example is the maintenance electrician is replacing solenoids on a gas annealing furnace. He needs the gas supply shut off. There’s no lock for the handle, so he turns it to the off position, removes the handle, and hangs a tag on it. Then he’s got the operator UI to worry about. He can’t lock it out, but he can use it to turn the controls to the shutdown mode, then unplug the cable that runs to the operator screen (he can hang a tag on both the cable and the screen).
