OSHA 29 CFR 1910.147 outlines “alternative protective measures” procedures that can improve efficiency without compromising operational safety. This exception is also referred to as a “minor service exception”. Designed for machine tasks that require frequent and repeated visits (for example, clearing blockages on conveyor belts or small tool changes). Alternative measures do not require complete power cuts.
Examples of alternative method technologies include key-controlled locks, control switches, interlocking guards, and remote equipment and disconnection. This may also mean locking only part of the device instead of the entire machine.
The latest ANSI standard “ANSI/ASSE Z244.1 (2016) Control of Hazardous Energy-Locking, Tagging, and Alternative Methods” has agreed with OSHA that workers should be protected from accidental equipment activation or potential leakage of hazardous energy. However, the ANSI committee did not attempt to fully comply with every historic OSHA compliance requirement. Instead, the new standard provides extended guidance beyond OSHA’s regulatory constraints on “routine, repetitive, and production operations indispensable” tasks.
ANSI makes it clear that LOTO should be used unless the user can prove that a complete alternative method will provide effective protection. In situations where the task is not well understood or risk assessed, lockout should be the default protective measure applied to control the machine or process.
Section 8.2.1 of ANSI/ASSE Z244.1 (2016) stipulates that it should be used only after it has been assessed and recorded that the technology used will cause negligible harm through the application of practical (or demonstration) studies alternative method. There is a risk of sudden start or no risk.
Following the control hierarchy model, ANSI/ASSE Z244.1 (2016) provides detailed guidance on whether, when, and how to apply a series of alternative control methods to provide equal or better protection for personnel performing specific tasks. In addition, it also details alternative risk reduction methods for some new technologies, including packaging, pharmaceuticals, plastics, printing and steel industries; semiconductor and robotics applications; and others who are challenged by current regulatory restrictions.
At this point, it should be emphasized that LOTO provides the highest level of protection, and where possible, it should be used to protect employees from hazardous energy sources. In other words, the inconvenience alone is not an acceptable excuse to use alternative measures.
In addition, CFR 1910.147 clearly states that permitted alternative measures must provide the same or higher level of protection as LOTO. Otherwise, it is considered non-compliant and therefore not sufficient to replace LOTO.
By using standard safety-level equipment—such as interlocking doors and emergency stop buttons—plant managers can achieve safe and reliable machine access, replacing standard LOTO procedures without violating OSHA requirements. Implementing alternative procedures to ensure equal protection for specific tasks can increase productivity without endangering employees. However, these procedures and their benefits are subject to conditions and require a thorough understanding of the latest OSHA and ANSI standards.
Editor’s note: This article represents the independent views of the author and should not be interpreted as endorsement by the National Security Council.
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Post time: Aug-28-2021