Understanding lockout/tagout roles and exceptions

When equipment breaks down or just needs routine maintenance, you probably have workers following lockout/tagout procedures. OSHA defines three categories of workers who may be involved:

Authorized employees apply the locks or tags to the machines and perform the actual service or maintenance. These workers are trained to follow special procedures designed to prevent injuries, such as releasing stored energy.

Affected employees are workers whose jobs require using machines being serviced under lockout/tagout, or whose jobs require working in an area where that service or maintenance is performed. They are “affected” by the lockout because they cannot use the equipment being serviced. If an affected employee’s duties include performing service or maintenance, that person must be trained as an authorized employee.

Other employees are those who may need to work in an area where energy control procedures are used. The OSHA regulation requires instructing these “other employees” about the energy control procedure and the prohibition against attempting to restart machines being serviced. This category could include many workers in the facility. It could also include temporary workers from a staffing agency.

Wherever lockout procedures are used:

• Make sure everyone knows their role, and make sure unauthorized workers do not perform service or maintenance that they haven’t been trained to perform.
• Ensure that other workers in the area (including temps from a staffing agency) understand the purpose of the lockout procedures and don’t interfere with them.
   

Lockout exceptions

OSHA provides some exceptions that allow for equipment service or maintenance without using lockout procedures.

The first is for “cord and plug” equipment. If a tool or machine can simply be unplugged, and the worker performing the service remains in control of the plug, then lockout procedures aren’t necessary.

The second exception is for minor service. Minor tool changes, adjustments, or routine tasks that are integral to production might not require lockout procedures. However, if a worker must bypass a guard or place any part of the body in a danger zone, the minor service exception won’t apply. Workers must use other procedures that provide protection, such as using a long tool to reach into a machine rather than reaching their hands into the machine.

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