Machine Lockout Tagout

[billsnuff]

I agree Jim. It also makes a difference if the individual is an 'authorized' person or an 'authorized' and 'qualified' person.

 

[weressl]

The general OSHA standards do not explicitly state exact steps that must be followed in a LOTO program as it is up to each employer to develop their own policies. However, 1910.147 APP A does list an example of procedures that are acceptable to OSHA and may be included in a LOTO program.

Correct.

Appendix A has the same authority as the blue notes in the Handbook: none.

I acknowledge that it is published by OSHA, but it is set apart from what is law. They use the words 'example' and 'may be included' as weaselwords to retain the final determination of the program content with the employer along with liability.

 

[Don S.]

NEC requirements, OSHA rules, Qualified Employees, are all nice but unless you thoroughly understand your equipment or system you can get in trouble. A bump test is not going to allow for stored energy, or that a control device is temporarily preventing machine movement. Verifying no voltage on the load side of a main feed does not account for the possibility of voltage on a control circuit from a separate source. Verified to be de-energized switchgear has been known to come live via a back feed. Rules & regulations are a good safety starting point. It takes specific equipment or system knowledge to really be safe.

 

[jim dungar]

Correct.

Appendix A has the same authority as the blue notes in the Handbook: none.

I acknowledge that it is published by OSHA, but it is set apart from what is law. They use the words 'example' and 'may be included' as weaselwords to retain the final determination of the program content with the employer along with liability.

OSHA does not explicitly state the step to follow, so you will not find a "you can or cannot" in their general standards. It is not weaselwording.

The law says that each employer must create their own LOTO procedures. The appendix contains verbiage and procedures that OSHA would probably accept in a LOTO procedure. Therefore an employer may include a "bump test" as part of their 'mechanical' LOTO. NFPA 70E explicitly does not allow a 'bump test' as a means of verifying LOTO for working on 'electrical' components.

 

[weressl]

OSHA does not explicitly state the step to follow, so you will not find a "you can or cannot" in their general standards. It is not weaselwording.

The law says that each employer must create their own LOTO procedures. The appendix contains verbiage and procedures that OSHA would probably accept in a LOTO procedure. Therefore an employer may include a "bump test" as part of their 'mechanical' LOTO. NFPA 70E explicitly does not allow a 'bump test' as a means of verifying LOTO for working on 'electrical' components.

Jim, I agree.

The weaselword comment pretained to the issue that emerged early in this thread that bump test "is allowed by the code (both OSHA and NFPA70E) as a verification test for removal of energy." So while it is clear to you (and me) that it alone MAY not be sufficent for verification by OSHA and definelty NOT acceptable to NFPA, some may read it is so.