Minor-servicing exception for machine shop tool changes

OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."

May 17, 2002

Mr. Larry L. Fagan

[Recipient address omitted]

Dear Mr. Fagan:

Thank you for your August 5, 2001 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had specific questions regarding the “Control of Hazardous Energy (Lockout/Tagout)” §1910.147 standard. Your paraphrased scenario, question, and our reply follow:

Scenario: Our shop is a single-employee operation in which I maintain complete and exclusive control of all the equipment switches and controls. Changing drill bits, reams, mills, and re-arranging parts in surface grinders is integral to the normal parts manufacturing process. Any occasion in which I must actually do equipment repairs in the machine shop or remove safety guards to change grinding wheels, the lockout/tagout standard requirements are followed. I do not consider these minor tool changes or minor adjustments to be any different from a normal production operation supporting composite can making production machinery.

Question: Would these minor servicing activities on the machine shop equipment be covered by the OSHA lockout/tagout standard?

Reply: The lockout/tagout standard, §1910.147, addresses the safety of employees engaged in servicing and maintenance activities, which include the machine or equipment setup activities that you have described. The fact that the servicing tasks are performed during normal production operations does not, in itself, exempt this activity from the lockout/tagout standard. Rather, such servicing tasks must be performed in accordance with the lockout/tagout standard unless they meet the conditions of either the “minor servicing” exception of §1910.147(a)(2)(ii) or the cord and plug electric connected electric equipment exception of §1910.147(a)(2)(iii)(A).

Minor tool changes and minor adjustments are covered by the lockout/tagout standard unless all of the §1910.147(a)(2)(ii) minor servicing exception provisions are met. Servicing activities that are minor in nature and that take place during normal production operations are not covered by the lockout/tagout standard if they are routine, repetitive, and integral to the production operation, provided that there is an effective alternative means used for employee protection in lieu of lockout or tagout.

While your letter does not contain sufficient detail to determine conclusively whether each of the activities that you have listed would be performed during normal production operations and would be routine, repetitive, and integral to the use of the respective pieces of machinery, other employers have demonstrated that similar activities can meet these criteria. If the tasks that you described do meet these criteria, you still must provide effective alternative protection, if the tasks require any employee (including yourself) to place any part of his or her body into an area where an associated danger zone exists during normal machine operation. Machine guarding and specialized tools that prevent employees from being exposed to hazardous energy during servicing and maintenance traditionally have been used to provide effective, alternative protection pursuant to the “minor servicing” exception.

The provisions of the lockout/tagout standard also may be inapplicable for work on cord and plug connected electric equipment. See 1910.147(a)(2)(iii)(A). However, the lockout/tagout requirements can be avoided for work on cord and plug connected electric equipment only when exposure to hazardous energy can be controlled completely be unplugging the equipment from the energy source and when the plug (once removed from the electric source) is under the exclusive control of the employee doing the servicing and maintenance work.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director

Directorate of Compliance Programs