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Relationship of 1910.147, The Control of
Hazardous Energy (Lockout/Tagout) Standard, to 1910.269, Electric Power Generation,
Transmission, and Distribution Standard, and 1910.333, Selection and Use of Electrical
Work Practices Standard
Lockout/Tagout and Selection and Use of Electrical Work Practices Standard
The Lockout/Tagout standard,
29 CFR 1910.147, does not cover exposure to
electrical hazards from work on, near, or with conductors or equipment in electric
utilization installations, which is covered by Subpart S. OSHA Subpart S is intended to
cover safety requirements that are necessary for the practical safeguarding of employees.
It does not cover other equipment-related hazards that do not involve exposed electrical
parts.
The requirements contained within the Lockout/Tagout standard
for deenergizing machines and equipment are similar to the requirements for Selection and
Use of Electrical Work Practices standard,
29 CFR 1910.333. The Selection and Use of Electrical
Work Practices standard covers work on or near exposed, deenergized electrical parts and
includes the necessary requirements for lockout and tagging of the means of disconnecting
equipment. However, the standard does not address a mechanic servicing the mechanical
parts of an electrically-powered machine, which is covered under the Lockout/Tagout
standard.
Energy Control Programs for the Lockout/Tagout and Use of
Electrical Work Practices Standard
29 CFR 1910.147(c)(1) of the Lockout/Tagout standard and
29 CFR 1910.333(b)(2) of the Selection and Use of Electrical Work Practices standard require
the employer to develop energy control procedures. As specified in Note 2 to
29 CFR 1910.333(b)(2) of the Selection and Use of Electrical Work Practices
standard, it would be acceptable for an employer to develop energy control
procedures in accordance with the Lockout/Tagout standard to fulfill the
requirements of
29 CFR 1910.333(b)(2) of the Selection and Use of Electrical Work Practices
standard. As further specified in Note 2, however, the employer's procedures
must also meet the requirements in
29 CFR 1910.333(b)(2)(iii)(D) and
29 CFR 1910.333(b)(2)(iv)(B) of the Selection and Use of Electrical Work Practices standard. This enables
an employer to use a single lockout and tagout program to cover all hazards addressed by
both these standards, as long as the program includes procedures that meet the two
additional paragraphs when exposure to electric shock is involved.
In comparing proposed
29 CFR 1910.333(b)(2) with final
29 CFR 1910.147, OSHA
determined that the new generic lockout standard encompassed all the lockout and tagging
requirements contained in the electrical work practices proposal with two exceptions.
First, the proposed electrical standard more tightly restricted the use of tags without
locks and called for additional protection when tags were permitted. Secondly, the
electrical work practices proposal contained specific requirements for testing circuit
parts for voltage before they could be considered as deenergized. OSHA believes that a
lockout and tagging program which meets
29 CFR 1910.147, will, with these two exceptions provide
protection for servicing and maintenance involving electrical work and live parts.
Accordingly, the final rule on electrical safety-related work practices incorporates this
finding. OSHA has decided to accept, by means of a note added to final
29 CFR 1910.333(b)(2), any
lockout and tagging program that conforms to
29 CFR 1910.147
if it also meets
29 CFR 1910.333(b)(2)(iii)(D) and
29 CFR 1910.333(b)(2)(iv)(B) of final
29 CFR 1910.333. This will enable employers to use a
single lockout and tagout program to cover all hazards addressed by these two standards,
as long as that program includes procedures that meet the two additional paragraphs when
exposure to electric shock is involved.
For additional information, refer to OSHA Directive
STD 01-16-007,
Electrical Safety-Related Work Practices -- Inspection Procedures and Interpretation Guidelines,
and the Preamble to the Lockout/Tagout standard,
29 CFR 1910.147.
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