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 requirements that pertain to energy control procedures [1910.147(c)(4)].

This starts by telling us procedures shall be developed, documented, and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by 1910.147. Those activities are the servicing and maintenance of machines and equipment in which the unexpected release of energy could cause injury to employees [1910.147(a)(1)(i)].

This requirement is followed by an exception. Unfortunately, OSHA’s style guide renders this in a typeface so small that many people will just skip over it as unreadable. There are eight conditions listed as grounds for not being required to have the aforementioned procedures, and all of them must be met. These include:

• A single lockout device will achieve a lockout condition.
• There’s no potential for stored energy once the machine is shut down. We have to remember that not all stored energy is electrical, so this bar is higher than it might seem.
• There have been no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

Then OSHA sets some requirements for the procedures. They must clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be used for the control of hazardous energy and the means to enforce compliance. One way to comply with this is to have sections that you name as follows: scope, purpose, authorization, rules, techniques, and compliance. That’s pretty clear and specific.

What does OSHA mean by “outline”? The idea is to allow people to see what these are without needing to digest huge blocks of text.

OSHA then says the procedures should include, but are not limited to the four items listed in 1910.147(c)(4)(ii)(A) through (D). For example, specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy.

One mistake procedure writers tend to make is they write these in narrative form, as if writing a tutorial for the untrained and unqualified. Another mistake is they explain the rationale for the  step. You get eye-glazing, bloated procedures that way. OSHA chose the word “outline” for good reasons, chief among them is you do not have to explain how to do the job if the person doing it is qualified to do it. But you do need to name the major steps involved.

So four sentences that tell the reader to go to the far west side of the 100 ton press, pull the black lever, etc. followed by one that reminds the reader that this is for the purpose of preventing crush injuries, can be replaced by “Lower ram to bottom position”. If he’s qualified to do the work in the first place, he’s going to understand that immediately. A paint by numbers set of instructions means taking the time to read it, think about it, and then conclude, “This must mean I need to lower the ram to the bottom position.” Why not just say that?