Standard 1910.147 covers the control of hazardous energy, which is also known as lockout tagout. Lockout tagout procedures are among the most difficult to institute and are even more difficult to maintain as a company changes over time. In 2011, this standard was responsible for nearly 4,000 citations. But, lockout tagout procedures are also crucially important, as a lockout tagout accident generally leads to serious injury or death, and led to 120 fatalities and 50,000 injuries in 2011.
The first thing to consider when setting your lockout tagout procedures is what, exactly, lockout tagout is. Per OSHA, lockout tagout procedures cover “the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees.” (1917.147 (a)(1)(i)) What this means is that any machine which can harm an employee at start up, or any other time through stored energy, must be included within the procedures. Employers must determine all of the isolation points within all of these machines, create standards to control this hazardous energy, and properly label the offending machines.
Unfortunately, it can be difficult to determine the isolation points, especially given the sometimes cryptic nature of this standard. It is for this reason we always recommend contacting a professional when establishing or updating procedures. Depending upon your particular needs, a consultation might suffice or a full audit might be required to ensure compliance. But whatever your need is, this is definitely one of those hazards where it is better to be safe than sorry.
For more information on creating lockout tagout procedures, or to schedule an audit, please contact us. And if you have anything to add about Standard 1910.147, please leave a comment.