The exception only applies if the employer offers effective alternative protection against hazardous energy. OSHA has determined that a reliable loop is an acceptable method to protect employees performing activities that fall under the minor maintenance exemption of the lock/labeling standard. In our letter of 15. In July 2003, we explained to David Teague (see attached copy) that “a circuit that meets the requirements of the U.S. National Standards for Machine Tools (ANSI B11.19-1990) for control component reliability and failure protection would provide alternative protections to the minor maintenance exception contained in 1910.147(a)(2)(ii).” As indicated in the letter to Mr. Teague, please note that mechanisms such as the one you mentioned can only be used in hazardous energy control situations where the other provisions of the minor maintenance exception apply. For machine design diagrams and accompanying job descriptions, include certain activities that may be maintenance and repair activities covered by the standard (e.g., Sheet Addition, Hopper Prestressing), and not the minor maintenance activities provided for in the standard exemption.1 Without direct observation of these tasks, We cannot determine with certainty whether they would fit within the minor maintenance exception. Your customer`s customers can contact OSHA`s free onsite consulting service for assistance in conducting a case-by-case risk analysis to determine the applicability of the minor maintenance exception for these activities. In your scenario, you specified that machine parts such as extendo, relief valves, and belts can be in service during minor maintenance work. It is assumed that locking the proposed on/off switch in the “Off” position would disable the machine and prevent movement in the machine parts. If this is not the case and workers are still exposed to risks arising from exposure to machinery during activities covered by the minor maintenance exemption, additional protective measures must be taken to ensure effective protection of workers.

Such a method would be to effectively protect potentially explosive areas of the machine, as required by Subdivision O – Protection of Machinery of Part 1910. Under no circumstances is an employee permitted to place any part of his or her body in a potentially explosive atmosphere (e.g. at the point of operation, incoming pinch points, or near power transmission equipment) unless all hazardous energies are effectively controlled. As you may know, the state of Minnesota manages its own occupational health and safety program with the approval and oversight of the federal OSHA. States that manage their own health and safety plans must adopt regulations that are “at least as effective” as federal regulations, though they may be stricter. As a result, Minnesota and other planned states may have more restrictive safety and health laws than federal laws. Therefore, if the equipment is installed in one of these state plan states, the customer should be aware that state health and safety laws may apply. For more information specific to the State of Minnesota, you can contact the Minnesota Department of Labor and Industry: OSHA`s Hazardous Energy Control Standard – the Lock Labeling Rule – (29 Code of Federal Regulations (CFR) 1910.147) addresses the safety of employees involved in maintenance and repair activities in general industry when exposure to the unexpected release of hazardous energy is possible.

The standard includes performance requirements that allow employers to develop lockout labelling programs that are appropriate for their respective facilities. There is another exception for lockout/tagout procedures under 1910.147(a)(2)(ii): To ensure the protection of your employees, an external equipment and machinery safety consultant can help. Choose a partner who understands OSHA requirements and has the right experience to perform a security audit and make recommendations to keep you compliant. That`s “all she wrote” for explicit exceptions in the standard, so I can`t say definitively that there are acceptable “alternative control methods” – perhaps you can enlighten me here? In general, anyone performing maintenance on machinery that may cause damage should be protected by locking/labeling procedures.