Examining the Minor Servicing Exemption to OSHA’s LOTO Standard
The scope of OSHA’s The Control of Hazardous Energy (Lockout/Tagout) standard covers “the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy.” The standard does not apply to normal production operations which by definition is the utilization of a machine or equipment to perform its intended production function.
However, within the application section of the standard, servicing and maintenance which takes place during normal production operations is covered if the following conditions exist.
- An employee is required to remove or bypass a guard or other safety device; or
- An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.
In essence, this implies the employee would be exposed to a hazard from energized equipment once the safeguarding barrier is removed or circumvented.
The standard’s succeeding note immediately following these two conditions cites the minor servicing exemption: Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).
Subpart O of this Part refers to OSHA’s Machinery and Machine Guarding standard which describes the general requirements for machine guards, including a provision for use of special hand tools for placing and removing material, along with detailed machine specific guarding requirements.
In meeting the minor servicing exemption, the conditions of routine, repetitive, and integral must all exist including and most importantly alternative measures which provide effective protection.