Employment / 1 min read
Given recent advances in safety cutoff systems found in newer manufacturing machinery, OSHA is considering a change to its lockout/tagout standard. OSHA's lockout/tagout standard regulates the control of hazards related to unexpected energization of manufacturing equipment during service, maintenance, and tool changes.
The standard requires that all sources of energy, including energy stored in the machine itself, be controlled during servicing, maintenance, and tool changes using an energy-isolating device (“EID”) such as circuit breakers, valves, and switches. Because of technological advances since the standard was implemented, OSHA has acknowledged that internal energy cutoffs found with newer manufacturing machinery may be at least as safe as EIDs. Many new manufacturing devices have been designed to undergo maintenance and tool changes in a safe manner without having to de-energize the entire machine.
Shutting down an advanced manufacturing machine is substantially different from simply locking out a traditional, standalone piece of industrial equipment. A full de-energization of computerized manufacturing equipment is often not practical, especially if de-energization requires significant time for a computerized manufacturing device to boot up or to be recalibrated.
Yet enforcement of the standard when applied to such advanced machinery can have serious consequences. OSHA can penalize serious violations of the standard with fines of up to $15,625 per infraction. An even more significant problem relates to abatement requirements for such violations. OSHA often requires a manufacturer to discontinue the use of the internal energy cutoff systems within the advanced manufacturing devices.
Manufacturers and other employers have increasingly asked OSHA to embrace safe robotic systems, often through requests for variances from the standard. OSHA may grant a variance if an employer can demonstrate the infeasibility of de-energization and the safety features that make maintenance of an energized system as safe as or even safer than adherence to the standard.