Lockout Tagout Hot Topics

The Lockout/Tagout standard makes a distinction between two types of workplace activities: Servicing and/or Maintenance and normal production operations. The Lockout/Tagout standard is intended to provide employees with protection from the unexpected energization, start up, or release of Stored Energy, while performing servicing and/or maintenance operations. The machine guarding standards in Subpart O are intended to provide employee protection against the Hazardous Energy associated with normal production operations. However, certain types of servicing and/or maintenance performed during normal production operations are also subject to the Lockout/Tagout standard.

Under the Lockout/Tagout standard, normal production operations are defined as the utilization of a machine or equipment to perform its intended production function.

Normal production operation is the mode in which an Energized machine or equipment operates to either manufacture a product or perform a function necessary to assist in the manufacturing process. This mode of operation may present additional hazards to employees, including points of operation; e.g. ingoing nip points, crushing hazards due to the motion of the machine or equipment and due to the movement of the power transmission apparatus. The machine guarding standards establish provisions for employee protection against Hazardous Energy and points of operation while the equipment is energized in order to perform its intended production function. (See 29 CFR 1910.212 and 29 CFR 1910.219).

Employee protection from Hazardous Energy during normal production operations is generally accomplished by Compliance with applicable machine guarding standards. However, if a Servicing or Maintenance operation takes place during normal production operations, and the employee is required to remove or bypass machine guarding required by Subpart O, or to place part of his/her body into an area in which he/she is exposed to the unexpected energization or activation of the equipment, the protections of the Lockout/Tagout standard would apply. In these circumstances, the employee performing servicing or maintenance would be subjected to hazards that are not encountered as part of the normal production operation.

Servicing and/or Maintenance is defined as workplace activities, including installing, setting up, inspecting, adjusting, repairing, replacing, constructing, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment, and making adjustments or tool changes, during which the employee may be exposed to the unexpected energization or startup of the equipment or release of Hazardous Energy. Setting up would include any work performed to prepare a machine or equipment to perform its normal production operation.

Many Servicing and/or Maintenance activities require the machine, equipment, or its components to be disassembled or dismantled. These tasks are typically performed with the equipment stopped. Other servicing and maintenance activities would not require the employer to disassemble or dismantle the machine or equipment but would nonetheless require shutdown of the equipment or machine. This would cause the associated production process to be discontinued during the servicing and maintenance.

Servicing and/or Maintenance activities may expose an employee to the unexpected energization, start up, or release of Stored Energy. The Lockout/Tagout standard establishes provisions to deenergize equipment in such cases and to render all potentially Hazardous Energy safe, prior to engaging in servicing and maintenance activities. These provisions are intended to protect employees from the equipment being Energized or started while servicing and/or maintenance is being performed.

Some Servicing operations performed during normal production operations are excepted from coverage under the Lockout/Tagout standard. This exception is referred to as the minor servicing exception. The Lockout/Tagout standard is not intended to cover minor servicing activities that are necessary to carry out the production process provided that associated danger zones are properly guarded. The machine guarding standards in Subpart O cover these types of operations.

The Lockout/Tagout standard contains specific criteria that must be met for the minor Servicing exception to apply. Minor tool changes and adjustments, and other minor servicing activities that take place during normal production operations, are not covered by the 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.

If the Servicing operation is routine, repetitive, and must be performed as part of the production process, the employer must use alternative protective methods or safeguarding devices (such as remote oilers and specially designed servicing tools), to protect employees.

Three specific criteria can be used to determine if the minor Servicing exception would apply to a particular activity.

First, the activity must be conducted during normal production operations, i.e., while the machine or equipment is actually performing its intended production function.

Second, the activity must be:
  • Routine: The activity must be a regular course of procedure and be in accordance with established practices.
  • Repetitive: The activity must be regularly repeated as part of the production process.
  • Integral: The activity must be essential to the production process.

Third, if all of these apply, the employer must use alternative measures to provide effective protection from the Hazardous Energy. Some acceptable alternative measures include specially designed tools, remote devices, interlocked barrier guards, local disconnects, or control switches which are under the exclusive control of the employer performing the minor Servicing. These alternative measures must enable the employee to safely perform the servicing task without being exposed to the unexpected energization or activation of the equipment, or the release of Stored Energy.

If the minor Servicing exception is not met in full, the Lockout/Tagout standard is applicable and the machine or equipment must be deenergized and all potentially Hazardous Energy rendered safe.

The preamble provides further clarification for routine, repetitive, and integral to the use of equipment for production.

For further information concerning group Lockout or Tagout in general, including examples of acceptable employer group lockout or tagout procedures, refer to The Control of Hazardous Energy - Enforcement Policy and Inspection Procedures. OSHA Directive CPL 02-00-147, (2008, February 11).

The Lockout/Tagout standard does not apply to Servicing and Maintenance operations if employees are not exposed to the risk of injury from the unexpected energization, start up, or release of Hazardous Energy while performing service or maintenance tasks.

Some Servicing or Maintenance activities do not expose workers to potential harm from the unexpected energization, startup, or release of Hazardous Energy because precautions taken by the employer provide effective employee protection when performing servicing and maintenance operations. These measures may include the use of a multi-step startup procedure, time delays, or audible warnings. In such relatively uncommon situations, Lockout/Tagout requirements do not apply. However, such alternative precautions must be carefully evaluated for their effectiveness in light of the configuration of the machinery, the reliability of the alternative measures, employee training, and other factors. Refer to The Control of Hazardous Energy - Enforcement Policy and Inspection Procedures. OSHA Directive CPL 02-00-147, (2008, February 11) which provides the framework for evaluating an employer's use of alternative procedures during servicing and maintenance operations.

The Lockout/Tagout standard does not apply to Servicing or maintaining cord- and plug-connected electrical equipment when the equipment is unplugged from its Energy Source and the plug is under the exclusive control of the employee performing the service and/or Maintenance activity. "Under the exclusive control" refers to instances in which the plug is physically in the possession of the employee, or in arm's reach and in the line of sight of the employee, or in which the employee has affixed a Lockout/Tagout device to the plug. This enables the employee to prevent the equipment from becoming reenergized during servicing or maintenance.

Printing Shop
In a printing shop, when a printing press is being used to produce printed materials, there is often the need to make minor adjustments such as to correct for paper misalignment while the press is running. This is a part of the production process, and is subject to the machine guarding requirements. The use of remote-control devices which keep the employees from reaching beyond the machine guards, or the use of inch (or jog) devices that permit machine speed control for test purposes obviate the need for Lockout/Tagout. However, printing presses may jam, requiring an employee to bypass the machine guards in order to reach the area of the jam and clear it. Although the need to unjam the machine arises during normal production operations, it is a Servicing activity that involves employee exposure to unexpected activation of the machine or release of energy, and is covered under the Lockout/Tagout standard.

Machine Shop
In a machine shop, a milling machine operator must adjust the flow of coolant oil to parts being milled while the cutting tool is in operation. This operation, which is part of the normal production process for the machine, is covered by the machine guarding requirements, which prevent employee contact with nip points and other points of operation. However, if it becomes necessary to perform an adjustment which requires the employee to bypass a guard or to place any part of his/her body in an area where work is performed on the material or where a danger zone exists during the machine's operating cycle, the Lockout/Tagout standard applies. If this step is performed without having to bypass the guard, reach into a danger zone, or otherwise expose the employee to the potential release of energy or the unexpected activation of the machine, the Lockout/Tagout standard would not apply.

Plastic Sheet Application Machine An employee is operating a machine that applies and seals a clear plastic sheet around a packaged product. There is a blade on the machine that cuts the plastic sheets, and this blade must be cleaned periodically during the production process. Since the process must be stopped to clean off the blade, that this operation is more in the nature of Servicing or Maintenance than normal production; on the other hand, since it must be performed frequently during production, it is arguable also part of the production process. Because the requirements of the Lockout/Tagout standard and Subpart O dovetail, protection must be provided regardless of whether the above operation is considered to be production or servicing. If it is considered by the employer to be production, the employee must be fully protected from the dangers of contacting the blade or other harmful machine parts; the cleaning must be done with special tools and procedures to provide the necessary protection. However, if it is considered to be servicing, outside of production, and the employee is exposed to a point of operation or an associated danger zone, the provisions of the Lockout/Tagout standard would apply.

The Directorate of Technical Support presents the 1910.147, Lockout/Tagout Interactive Training Program. We developed the program jointly with the Directorates of Compliance Programs, Safety Standards Programs, the Office of Training and Education, and the Office of the Solicitor. Compliance officers in Philadelphia, New York, and Atlanta assisted us as well.

Whether you are a recent hire or an experienced employee, this program will expand your knowledge of the Lockout/Tagout (LOTO) standard.

The program has three major components. You can go through these components at your own pace and in any sequence:
  • 29 CFR 1910.147 Explained: Explains the standard in a question/answer format.
  • Lockout/Tagout Hot Topics: Contains five abstracts with a detailed discussion of major issues. Relevant highlighted sections of the all-inclusive documents are linked here.
  • OSHA Case Studies: Seven simulated LOTO inspections are presented. You will be making decisions on the application of the LOTO standard, based on information presented on the screen.

A periodic inspection of each Energy Control Procedure must be performed at least annually to ensure that the energy control procedures continue to be implemented properly and that employees are familiar with their responsibilities under those procedures. The inspection must also ensure that the procedure is adequate to provide effective protection to the Authorized Employee during Servicing and Maintenance operations covered by this standard.

The employer is required to correct any deficiencies observed during the periodic inspection. Inadequacies in the Energy Control Procedure could be the result of using a general procedure that does not effectively handle a specific application. They also may arise from changes made to equipment or processes without modifying the existing energy control procedure.

The periodic inspection must be performed by an Authorized Employee other than the one(s) who is using the energy control procedures. This individual will be referred to as the "inspector." The inspector must be able to determine:
  •  Whether the steps in the energy control procedure are being followed.
  •  Whether the employees involved know their responsibilities under the procedure.
  •  Whether the procedure provides the necessary protection, and what changes, if any, are needed.

The periodic inspection consists of two requirements. First, the inspector must observe a representative sample of authorized employees performing the Servicing and Maintenance operation using the Lockout/Tagout procedure. Second, the inspector must perform a review with each Authorized Employee of that employee's responsibilities under the Energy Control Procedure being inspected. When the periodic inspection involves a Tagout procedure, the inspector's review of responsibilities extends to the affected employees as well, because of the increased importance of their role in avoiding accidental or inadvertent activation of the equipment or machinery being serviced or maintained.

The employee performing the periodic inspection does not have to observe every Authorized Employee implementing the Energy Control Procedure on the machine or equipment on which he or she is authorized to perform Servicing and Maintenance to meet the requirements of 29 CFR 1910.147(c)(6)(i)(C) and 29 CFR 1910.147(c)(6)(i)(D). The inspector participating in the review when Lockout is used needs to:
  •  Observe a representative number of such employees while implementing the procedure, and
  •  Talk with all other authorized employee even though they may not be implementing the energy control procedure.

It is not required that the periodic inspection be conducted in separate one-on-one meetings; it can involve the inspector meeting simultaneously with a group of authorized employees. Group meetings can be one of the most effective methods to conduct the inspection and make clear to the employees that they need to follow the procedure carefully.

The employer must certify that a periodic inspection has been performed at least annually. The certification must include information on each of the following:
  •  The machine or equipment on which the energy control procedure was used.
  •  The date of the inspection.
  •  The employees included in the inspection.
  •  The name of the inspector who performed the inspection.

The employer is required to provide effective training for all employees covered by the Lockout/Tagout Standard and ensure that all employees understand the purpose, function, and restrictions of the Energy Control Program. Authorized employees must possess the knowledge and skills necessary for the safe application, use, and removal of energy controls. This training also must make employees aware that disregarding or violating the energy control program could endanger their own lives or the lives of co-workers.

Employee Training Requirements
There are three types of employees which must receive training: authorized, affected, and other. The amount and type of training that each employee receives is based upon the relationship of that employee's job to the machine or equipment being locked or tagged out and upon the degree of knowledge relevant to Hazardous Energy that the employee must possess.

In addition, employers are required to certify that effective training and retraining has been provided to all employees covered by the standard. The certification must contain each employee's name and dates of training.
•  Authorized Employee Training: The Lockout/Tagout Standard requires that before the machine or equipment is turned off, the authorized employee must be knowledgeable of the following:
   - Recognition of applicable hazardous energy sources.
   - Details about the type and magnitude of the hazardous energy sources present in the work area.
   - The methods and means necessary to isolate and control hazardous energy sources.

•  Affected and Other Employee Training: Affected employees and all other employees are required to recognize when energy control procedures are being used, understand the purpose of the procedure, and understand the critical importance of not attempting to start up or use equipment that has been locked out or tagged out.

Additional Training Requirements for the Use of Tagout Devices
When the employer uses Tagout as opposed to Lockout, employees must receive additional training to enhance the safety of the tagout program and to ensure employee protection.

To address the limitations of tags, additional training must be conducted for employees who work with Tagout or who work in areas in which tagout is used. This additional training must address the following:
  •  Tags are essentially warning devices affixed to energy-isolating devices and do not provide the physical restraint of a lock.
  •  Tags must be legible and understandable by all employees.
  •  Tags and their means of attachment must be made of materials that will withstand the environmental conditions encountered in the workplace.
  •  The presence of tags may create a false sense of security. They are only one part of an overall energy control program.
  •  Tags must be securely attached to the energy control devices so that they cannot be detached accidentally during use.
  •  When a tag is attached to an isolating means, it is not to be removed except by the person who applied it, and it is never to be bypassed, ignored, or otherwise defeated.

Retraining
Retraining must be provided whenever there is a change in job assignments; a change in machines, equipment, or processes that presents a new hazard; or a change in energy control procedures. Additional retraining must be conducted whenever a periodic inspection reveals, or whenever the employer has reason to believe, that there are deviations from or inadequacies in the employees' knowledge or use of the Energy Control Procedure.

Retraining could be triggered by other events as well. For example, an employee working with an Energy Control Procedure might be injured in the course of his/her duties, or a "near miss" might occur in which no one is injured but a deviation from established energy control procedures occurred. Both of these cases would trigger the need for retraining.

Whenever Servicing and/or Maintenance is performed by a group of employees, the employer must develop and implement an Energy Control Procedure that provides authorized and affected employees with the same level of protection as a personal Lockout or Tagout device. The requirements for group lockout or tagout are set out in section 29 CFR 1910.147(f)(3).

Servicing and Maintenance operations performed by a group of employees are often more complex than servicing or maintenance performed by an individual. As a result, group Lockout or Tagout operations typically require more coordination and communication than personal lockout or tagout operations. Greater coordination between employees is particularly important when more than one craft or department must be involved to complete the task.

Under the standard's group Lockout/Tagout requirements, a single Authorized Employee must assume the overall responsibility for the control of Hazardous Energy for all members of the group while the Servicing or Maintenance work is in progress.

The Authorized Employee with the overall responsibility must implement the energy control procedures, communicate the purpose of the operation to the Servicing and Maintenance employees, coordinate the operation, and ensure that all procedural steps have been properly completed. In such operations, it is critical that each authorized employee involved in the group Lockout/Tagout activity be familiar with the type and magnitude of energy that may be present during the servicing and maintenance work.

In addition, each employee must affix his/her personal Lockout or Tagout device to the group Lockout Device, group lockbox, or comparable mechanism, before engaging in the Servicing and Maintenance operation. This enables the Authorized Employee to have control over his/her own protection, and verify that the equipment has been properly deenergized. Additionally, the lockout or Tagout device will inform other persons that the employee is working on the equipment, and as long as the device remains attached, the authorized person in charge of the group lockout or tagout knows that the work has not been completed and that it is not safe to reenergize the equipment.

The Servicing employee will continue to be protected by his/her Lockout or Tagout device until it is removed. The Authorized Employee in charge of the group lockout or tagout must not remove the group lockout or Tagout device until each employee in the group has removed his/her personal device, indicating that he/she is no longer exposed to the hazards from the servicing operation.

When the activities involving group Lockout or Tagout extend into another workshift, or there is a change of authorized employees, the provisions for shift or personnel changes must also be followed.

Work authorization permits may play a role in an employer's group Lockout/Tagout Procedures. A work authorization permit is a document authorizing employees to perform specific tasks. While the Lockout/Tagout standard does not specifically require the use of a work authorization permit, these documents may be used as a means of achieving Compliance with the group lockout or tagout requirements.

If a work authorization permit is used to achieve Compliance with group Lockout/Tagout provisions, it must be included in the employer's written procedures. The permit must identify the equipment to be serviced, the types and unique energy characteristics to be encountered, methods for safe work, and the process or procedures to be used to accomplish the task.

For additional information on work authorization permits and group Lockout/Tagout Procedures, see the Preamble at Vol. 54, Federal Register Page 36683.

For further information concerning group Lockout or Tagout in general, including examples of acceptable employer group lockout or tagout procedures, refer to The Control of Hazardous Energy - Enforcement Policy and Inspection Procedures. OSHA Directive CPL 02-00-147, (2008, February 11).

Equipment or machines that are subject to the Lockout/Tagout standard may possess more than one type of Hazardous Energy. These may be in the form of mechanical, hydraulic, pneumatic, chemical, thermal, or other types of energy. Any such hazardous energy sources must be locked out/tagged out and all Stored Energy Dissipated and/or restrained before an Authorized Employee engages in any Servicing and Maintenance activity.

When authorized employees implement an Energy Control Procedure for a particular machine or equipment without regard for other machines or equipment in the area, they could still be subject to Hazardous Energy from interconnected or nearby machines or equipment.

Interconnected Machines or Equipment If an Authorized Employee is exposed to the unexpected energization, start up, or release of Stored Energy from interconnected machines or equipment, the energy control procedures for all interconnected machines or pieces of equipment must be implemented.

For example: An Authorized Employee is changing a snapped belt on a motor. The authorized employee has deenergized and locked out the motor according to the Energy Control Procedure for that piece of equipment. The motor is located directly over the interconnected conveyor, which is stopped but has not been deenergized or locked out. The conveyor has a different energy isolation point than the motor and may have an auxiliary power source or the capacity to release Stored Energy and startup unexpectedly. The authorized employee must stand on the conveyor in order to replace the belt. If the conveyor were unexpectedly started, the authorized employee could be severely injured. Since the conveyor is interconnected and exposes the authorized employee to the potential for injury from unexpected startup, the energy control procedures for the motor must ensure that Servicing and Maintenance employees are not exposed to hazards posed by the conveyor. The energy control procedures for the motor must require that energy control procedures for the conveyor be implemented, as well.

Nearby Machines or Equipment If an Authorized Employee, in performing service and Maintenance work on a machine or piece of equipment, is exposed to Hazardous Energy from nearby machines or equipment, the employer is required to provide the employee with protection from these hazardous energy sources.

For example: Using the belt replacement scenario above, the Authorized Employee could be subject to the Hazardous Energy associated with a nearby production process where a robot arm is operating. When the robot arm operates, it could strike the authorized employee replacing the belt. In this event, the employer must provide protection from the hazardous energy associated with the nearby robot arm by either:
• Complying with the machine safeguarding standards and effectively guarding the nearby robot arm to not only protect the operators of the equipment but to protect servicing and maintenance employees replacing the belt.
• Locking out or tagging out the nearby robot arm if:
    The guarding is not adequate, or
    The design or installation of the equipment would not permit such machine safeguarding, or
    Compliance with the Lockout/Tagout standard, 29 CFR 1910.147, provides the only feasible method.

In either instance, the employer must ensure that Servicing and Maintenance employees are not subject to Hazardous Energy from nearby machinery and equipment while carrying out servicing and maintenance activities on machines or equipment.

The Lockout/Tagout standard does not cover installations under the exclusive control of electric utilities for the purpose of power generation, transmission, and distribution, including related equipment for communication or metering; these would be covered by the Electric Power Generation, Transmission, and Distribution standard, 29 CFR 1910.269

29 CFR 1910.269(d) and 29 CFR 1910.269(m) of the Electric Power Generation, Transmission, and Distribution standard specify the control of electrical energy requirements that apply to operations and Maintenance work. The Lockout/Tagout Procedures of 29 CFR 1910.269(d) apply to the control of electrical energy in installations for the purpose of electric power generation, including related equipment for communication or metering. The locking and tagging procedures of 29 CFR 1910.269(m) apply to deenergizing of electric energy sources that are used exclusively for purposes of transmission and distribution.

29 CFR 1910.269(d)(1) notes that installations in electric power generation facilities that are not an integral part of, or inextricably commingled with, power generation processes or equipment are covered under the Control of Hazardous Energy standard and Subpart S.

Energy Control Programs for the Lockout/Tagout and Electric Power Generation, Transmission, and Distribution Standard

29 CFR 1910.269(d)(1) limits the application to energy sources in installations for the purpose of electric power generation, including related equipment for communication or metering. The scope of this paragraph of the standard is intended to coincide with the exemption from the Lockout/Tagout standard which is described in 29 CFR 1910.147(a)(1)(ii)(B). Electrical installations in electric generating plants that are not addressed in 29 CFR 1910.269(d) are covered in 29 CFR 1910 Subpart S.

Note: The existing electrical regulations contained in Subpart S, including the Electrical Safety-Related Work Practices lockout and tagging requirements, address electrical utilization systems (e.g., installations of electrical conductors and equipment which uses electric energy for mechanical, chemical, heating, lighting, or similar purposes).

29 CFR 1910 Subpart S protects most employees from the hazards associated with electrical utilization equipment and with the premises wiring that supplies this equipment.

This scope description coincides with the electrical utilization system exemption provisions of 29 CFR 1910.147(a)(1)(ii)(B). The following OSHA Instructions should be consulted for Compliance policy and guidance purposes:
  • Enforcement of the Electric Power Generation, Transmission, and Distribution Standard. OSHA Directive CPL 02-01-038 [CPL 2-1.18A], (2003, June 18). Discusses the Electrical Power Generation, Transmission, and Distribution standard.
  • The Control of Hazardous Energy - Enforcement Policy and Inspection Procedures. OSHA Directive CPL 02-00-147, (2008, February 11). Discusses the Control of Hazardous Energy standard.
  • Electrical Safety-Related Work Practices - Inspection Procedures and Interpretation Guidelines. OSHA Directive STD 01-16-007 [STD 1-16.7], (1991, July 1). Discusses the Selection and Use of Work Practices standard.

Hazardous Energy control procedures in 29 CFR 1910.269(d), with the exception of 29 CFR 1910.269(d)(8)(v), (dealing with centrally located control facilities), are taken nearly verbatim from 29 CFR 1910.147. Both section 29 CFR 1910.147(c) of the Lockout/Tagout standard and 29 CFR 1910.269(d) of the Electric Power Generation, Transmission, and Distribution standard require the employer to develop an Energy Control Program consisting of energy control procedures, employee training, and periodic inspections. An energy control program that complies with the requirements of the Lockout/Tagout standard would also meet the requirements of 29 CFR 1910.269(d)(2)(ii), as long as the program addresses the hazards covered by paragraph 29 CFR 1910.269(d) of the Electric Power Generation, Transmission, and Distribution standard.

29 CFR 1910.269(m) of the Electric Power Generation, Transmission, and Distribution standard specifies procedures for the deenergization of electrical energy sources used exclusively for purposes of transmission or distribution. Implementing the procedures under the Lockout/Tagout standard, 29 CFR 1910.147 does not fulfill the requirements for implementing energy control procedures under 29 CFR 1910.269(m) of the Electric Power Generation, Transmission, and Distribution standard when deenergizing electrical energy sources used for transmission or distribution. Refer to OSHA Directive CPL 02-01-038 for additional information.

The Lockout/Tagout standard, 29 CFR 1910.147, does not cover exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations, which is covered by Subpart S. OSHA Subpart S is intended to cover safety requirements that are necessary for the practical safeguarding of employees. It does not cover other equipment-related hazards that do not involve exposed electrical parts.

The requirements contained within the Lockout/Tagout standard for deenergizing machines and equipment are similar to the requirements for Selection and Use of Electrical Work Practices standard, 29 CFR 1910.333. The Selection and Use of Electrical Work Practices standard covers work on or near exposed, deenergized electrical parts and includes the necessary requirements for Lockout and tagging of the means of disconnecting equipment. However, the standard does not address a mechanic Servicing the mechanical parts of an electrically-powered machine, which is covered under the Lockout/Tagout standard.

Energy Control Programs for the Lockout/Tagout and Use of Electrical Work Practices Standard

29 CFR 1910.147(c)(1) of the Lockout/Tagout standard and 29 CFR 1910.333(b)(2) of the Selection and Use of Electrical Work Practices standard require the employer to develop energy control procedures. As specified in Note 2 to 29 CFR 1910.333(b)(2) of the Selection and Use of Electrical Work Practices standard, it would be acceptable for an employer to develop energy control procedures in accordance with the Lockout/Tagout standard to fulfill the requirements of 29 CFR 1910.333(b)(2) of the Selection and Use of Electrical Work Practices standard. As further specified in Note 2, however, the employer's procedures must also meet the requirements in 29 CFR 1910.333(b)(2)(iii)(D) and 29 CFR 1910.333(b)(2)(iv)(B) of the Selection and Use of Electrical Work Practices standard. This enables an employer to use a single lockout and tagout program to cover all hazards addressed by both these standards, as long as the program includes procedures that meet the two additional paragraphs when exposure to electric shock is involved.

In comparing proposed 29 CFR 1910.333(b)(2) with final 29 CFR 1910.147, OSHA determined that the new generic Lockout Standard encompassed all the lockout and tagging requirements contained in the electrical work practices proposal with two exceptions. First, the proposed electrical standard more tightly restricted the use of tags without locks and called for additional protection when tags were permitted. Secondly, the electrical work practices proposal contained specific requirements for testing circuit parts for voltage before they could be considered as deenergized. OSHA believes that a lockout and tagging program which meets 29 CFR 1910.147, will, with these two exceptions provide protection for Servicing and Maintenance involving electrical work and live parts. Accordingly, the final rule on electrical safety-related work practices incorporates this finding. OSHA has decided to accept, by means of a note added to final 29 CFR 1910.333(b)(2), any lockout and tagging program that conforms to 29 CFR 1910.147 if it also meets 29 CFR 1910.333(b)(2)(iii)(D) and 29 CFR 1910.333(b)(2)(iv)(B) of final 29 CFR 1910.333. This will enable employers to use a single lockout and Tagout program to cover all hazards addressed by these two standards, as long as that program includes procedures that meet the two additional paragraphs when exposure to electric shock is involved.

For additional information, refer to OSHA Directive STD 01-16-007, Electrical Safety-Related Work Practices -- Inspection Procedures and Interpretation Guidelines, and the Preamble to the Lockout/Tagout standard, 29 CFR 1910.147.