manufacturers must develop energy control plans and specific procedures for each machine. They recommend posting a step-by-step lockout/tagout procedure on the machine to make it visible to employees and OSHA inspectors. The lawyer said that the Occupational Safety and Health Administration will inquire about hazardous energy policies, even if they make another type of complaint on the spot.
Wachov said the company trains plant employees and maintenance personnel; they should use OSHA’s hazardous energy control terminology at least part of the time so that they know the correct wording when inspectors ask workers.
Smith added that the person who puts the lock tag on the machine must be the person who removes it after the work is complete.
“The question we have is whether we can argue that something is in normal production, I don’t have to lock/list, because disconnecting all energy can be a very complicated procedure,” she said. Minor tool changes and adjustments and other minor maintenance activities are okay. “If this is routine, it is repetitive and an integral part of machine use, you can use alternative measures to protect the employee,” Smith Say.
Smith proposed a way to think about it: “If you want to make an exception in the lockout/tagout procedure, do I put employees in a dangerous area? Do they have to put themselves in the machine? Do we have to bypass the guards? That really is Is it’normal production’?”
The Occupational Safety and Health Administration is considering whether to update its lockout/tagout standards to modernize the machine without affecting the safety of workers during machine service and maintenance. OSHA first adopted this standard in 1989. Lockout/tagout, OSHA also calls it “Hazardous Energy Control”, and currently requires the use of Energy Isolation Devices (EID) to control energy. Circuit-controlled equipment is clearly excluded from the standard. “Nevertheless, OSHA recognizes that since OSHA adopted the standard in 1989, the safety of control circuit-type equipment has improved,” the agency said in its explanation. “As a result, OSHA is reviewing the lockout/listing standards to consider whether to allow the use of control circuit-type equipment instead of EID for certain tasks or under certain conditions.” OSHA said: “Over the years, some employers have stated that they believe that the use is approved The components, redundant systems, and control circuit-type devices that control reliable circuits are as safe as EID.” The agency stated that they may reduce downtime. Washington-based OSHA is part of the U.S. Department of Labor and is seeking opinions, information, and data to determine what conditions (if any) can be used to control circuit-type equipment. The agency stated that OSHA is also considering revising the lockout/tagout rules for robots, “this will reflect new industry best practices and technological advancements in hazardous energy control in the robotics industry.” Part of the reason is the emergence of collaborative robots or “collaborative robots” that work with human employees. The Plastics Industry Association is preparing comments to meet the agency’s August 19 deadline. The Washington-based trade organization issued a statement encouraging plastic processors to provide advice to OSHA because the shutdown/listing mainly affects users of plastic machinery—not just machinery manufacturers. “For the U.S. plastics industry, safety is of paramount importance — for the thousands of companies that comprise it and the hundreds of thousands of workers who make it a reality. [Plastics Industry Association] supports modern regulatory standards and allows effective use of Technology advancements to control hazardous energy, and are eager to help OSHA in current and future rulemaking,” the trade association said in a prepared statement.
Post time: Jul-31-2021