The Minor Servicing Exemption LOTO’s Misunderstood Requirement Carlos Gallegos Assistant Area Director - Response Team Aurora Area Office [email protected] Goals • Review LOTO application – Define employee roles – Review Acceptable Isolation Devices – Compare Machine Guarding to LOTO – Special Equipment/Circumstances • Discuss the “Minor Servicing Exception” 1 Goals • Review Machine Guarding – When is Machine Guarding sufficient • Related Standards • E-Stops • Performance and Control Reliability – Safeguards – Circuit Integration (relays + contactors) • Examples of machine guarding in Minor Servicing Region V Top 10 Most Frequently Cited (Manufacturing) 348 350 300 250 168 200 156 153 133 127 150 99 92 85 84 100 50 0 5 National Top 10 Most Frequently Cited (Manufacturing FY-16) 1169 679 563 499 497 446 316 312 301 282 6 2 Presentation References • 29 CFR 1910.147 The Control • ANSI B11.19-2010 American of Hazardous Energy National Standard for (Lockout/Tagout) Machines – Performance Criteria for Safeguarding • CPL 02-00-147 The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures Definitions • "Affected employee." An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed. 1910.147(b) 8 Definitions • "Authorized employee." A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. • An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section. 1910.147(b) 3 Authorized Employee (CPL:Pg 1-4) • Any employee who implements a lockout and/or tagout system procedural element on machines or equipment (for servicing and/or maintenance purposes) is considered an authorized employee: – perform energy source isolation; – implement lockout and/or tagout on machines or equipment; – dissipate potential (stored) energy; – verify energy isolation; – implement actions to release LOTO; or – test or position machines or equipment. Required Training • Authorized employees – Recognition of hazardous energy sources – Type and magnitude of energy in the workplace – Methods for energy isolation / control • Affected employees – Purpose and use of energy control procedures • Other employees in work area – Procedures related to restarting machines 11 Servicing and/or Maintenance (CPL:Pg 1-10) • Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. • These activities include lubrication, cleaning or un-jamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or start-up of the equipment or release of hazardous energy. 4 Energy Isolating Device (CPL:Pg 1-5) • A mechanical device that physically prevents the transmission or release of energy. • Push-buttons, selector switches, safety interlocks and other control circuit type devices are NOT energy isolating devices. Alternative Effective Protection? • Employee reaches into the die in a hydraulic press to clean die surface, which is done about once an hour. • The press has a light curtain for protection. Assume this is minor servicing work. • Is the employee considered authorized or affected? 14 Adequate device for energy isolation? 5 CPL 02-00-147; Pgs. 3-25 Thru 3-32 MINOR SERVICING EXCEPTION TO THE LOCKOUT/TAGOUT STANDARD Lockout/Tagout & Employee Protection (CPL:Pg. 2-16) • Employee Protection for Service & Maintenance Activity is achieved by: – Apply Full LOTO I/A/W 29 CFR §1910.147; – Complying with the minor servicing exception to the LOTO standard (1910.147(a)(2)(ii)) • Machine Guarding – Must provide effective employee protection. – Utilizing the cord and plug connected equipment or hot tap exemptions – i.e., 1910.147(a)(2)(iii)(A) and (a)(2)(iii)(B); – Complying with the machine or equipment testing or positioning requirements of 1910.147(f)(1); • Machine Guarding – Must provide effective employee protection. LOTO Scope • 1910.147(a)(2)(ii) – Normal production operations are not covered by this standard (See Subpart O of this Part). Servicing and/or maintenance which takes place during normal production operations is covered by this standard only if: • An employee is required to remove or bypass a guard or other safety device; or • An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle. 6 Minor Servicing Exception • Exception to paragraph (a)(2)(ii) – Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part). Lockout/Tagout & Machine Guarding Employee Exposure Servicing & Maintenance Normal Production Activity Operations Subpart O 29 CFR 1910.147 29 CFR 1910.212 - 219 Employee Exposure Lockout/Tagout & Machine Guarding Employee Exposure Servicing & Maintenance Normal Production Activity M Operations S Subpart O 29 CFR 1910.147 E 29 CFR 1910.212 - 219 Employee Exposure 7 Minor Servicing Exception • In order to take advantage of the limited exception, an employer must provide effective alternative protection in lieu of LOTO. Lockout/Tagout & Machine Guarding Guarded Guarded Guards & Safeguarding Devices to ELIMINATE employee exposure during the servicing and maintenance activity. Minor Servicing Exception • Minor “servicing and/or maintenance” activities: – Do not require extensive disassembly of the machinery/equipment. – Can be accomplished safely with effective production-mode safeguards, (Subpart O). 8 Minor Servicing Exception (CPL:Pg. 3-26) • Activities requiring machine or equipment shutoff and disassembly, such as changing a machine tool or cutting blade, usually take place outside of the normal production process and require energy isolating device LOTO in accordance with §1910.147. – Changing Table Saw blade. – Changing Grinding Wheel, etc. • Replacement of machine or equipment components normally is not considered a routine maintenance function that can be safely accomplished when a machine or piece of equipment is operating. – belts, valves, gauges, linkages, support structure, etc. -- Service/ Region V Minor Servicing (1910.147(a)(2)(ii)) Maintenance Activity/ EE Exposure to Hazard Decision Flow Chart * Inherent & Minor - Activities must be Normal Lockout necessary to allow production to Production NO Applies to All Operation? Service/Maint proceed and be: Routine: The activity must be performed as part of a regular and YES prescribed course of procedure and be performed in accordance Service/ with established practices. Maintenance Lockout Inherent & NO Applies Repetitive: The activity must be Minor?* repeated regularly as part of the production process or cycle. YES Integral: The activity must be inherent to the production process. Effective Lockout Protection In NO Applies Use? ** ** Employer must demonstrate that the alternative measures provide YES effective protection from the hazardous energy. Exception Applies to (Subpart O; ANSI B11.19-2003; etc.) Service/Maintenance MSE Operator Initiated Safety • Is it acceptable to have the employee follow a procedure to place the machine in a safe mode, manual mode or pause the operation as a part of the MSE effective protection? • NO! – With the exception of certain low risk equipment and tasks. 9 Westvaco Corporation Decision (CPL:Pg. 3-26) • OSHA issued a citation alleging a serious violation of §1910.147 because an employer did not lockout or tagout the slotter section of a printer/slotter machine. Adjustments to both the printer section and the slotter section had to be made for each order. The average number of orders run per day was three or four and each order change required set-up adjustments taking between 15 and 45 minutes to complete. Westvaco Corporation Decision • What did the OSHRC decide and why? – Rejected the employer's assertion that set-up activities associated with this equipment constituted minor servicing within the scope of the exception. – Commission Concluded • setting up does not occur during normal production operations • work performed before the normal production operation is not covered by the exception Westvaco Corporation Decision • While not reaching the questions of whether the activities were minor [as are included in this exception] or whether the alternative protection was effective, the Commission concluded that adjustments made while the machine was being set-up were not adjustments made during normal production operations. 10 MSE Operator Initiated Safety • Must have a guard or safety device, properly selected and applied based on generally accepted good engineering practices. (ANSI B11.19) • A procedure that involves and requires the employee to initiate the safe condition is an Administrative Control. Hierarchy of Control PROTECTIVE MEASURE EXAMPLES Most Effective Elimination or •Eliminate human