Minor service misconceptions under lockout/tagout

The OSHA lockout/tagout regulation allows certain minor services to be performed without using lockout/tagout. However, the regulation clearly states that lockout requirements still apply if an employee must remove or bypass a guard, or place any body part into a point of operation.

The minor service provision might apply to activities that are part of normal production such as clearing jams, applying lubrication, or making tool changes — but only if those duties can be performed safely, without putting a hand or other body part in a danger zone. Further, these tasks are exempted form the lockout standard only if:

• They are routine, repetitive, and integral to the use of the equipment; and
• The work is performed using alternative measures which provide effective protection.
   

Routine, repetitive, and integral

To qualify for the exception, the minor service work must be necessary for production to proceed without interruption. OSHA says that the minor service exception applies only if applying LOTO “would prevent the machine from economically being used in production.”  In addition, the work must be:

• Routine: The activity must be performed as part of a regular procedure,
• Repetitive: It must be repeated during the production process, and
• Integral: The activity must be inherent to the production process.

Adjustments or maintenance that fail to meet any one of those criteria cannot qualify for the minor service exception.

Protection for employees

If an employee must bypass guards or would be exposed to hazardous energy, then the minor service exception does not apply. For instance, if clearing a jam requires reaching a hand into a hazard area, it doesn’t qualify as minor service.

To avoid the lockout/tagout requirements, you must protect employees from hazardous energy using guards or other measures. Alternative protection might involve an interlocked guard that prevents the machine from operating while the guard is open or removed, or clearing a jam by using a special tool that negates the need for an employee to reach into a point of operation.

If any routine maintenance is done without applying lockout/tagout, review those tasks to verify that they meet all elements of the minor service exception. If employees are exposed to hazardous energy, you either need to apply lockout procedures, or identify methods that would allow them to perform the task without exposing themselves to hazards.

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