The proposed amendments may present challenges for machine manufacturers and manufacturers who wish to use advanced control systems for operation and safety.
In October, the Occupational Safety and Health Administration (OSHA) proposed to change its hazardous energy control (lockout/tagout) standard (29 CFR part 1910.147). This standard was created in 1989 and deals with the practices and procedures required to disable machinery or equipment to prevent the release of hazardous energy during repairs and maintenance by employees. To this end, it outlines measures to control the accidental activation or release of energy from electrical, mechanical, hydraulic, pneumatic, chemical, thermal or other energy sources in machines, which may seriously harm workers.
The change OSHA is now considering is to remove the word "accidental" from the lockout/listing description. The proposed changes are only one of 18 amendments related to existing standards in the fields of record keeping, general industry, maritime and construction-all of which are being reviewed as part of the OSHA Standards Improvement Project (SIP).
The amendment to lockout/listing aims to eliminate any confusion about the meaning of the term "accident". Specifically, OSHA believes that the term has been misunderstood to exclude startup operations or employee injuries due to the release of stored energy.
This was reviewed in the case of Reich v. General Motors Corp., Delco Chassis Div. (GMC Delco). One case is under review because workers are repairing machines that use eight to twelve-step start-up procedures, including time delays and audible or visual warnings. The court held that because these functions will warn service employees that the machine is about to start, the start will not be "accidental", so there is no need to follow the lockout/tagout procedure.
However, OSHA believes that the warning device is not as protective as the lockout/tagout procedure. Nevertheless, since the standard was released nearly 30 years ago, technology has made considerable progress, and the company has been adopting advanced systems to ensure safety and compliance. In order to explore the potential impact or problems that the amendment may cause, the Occupational Safety and Health Administration invited the industry to submit comments earlier this month.
According to Bruce Main, president of design safety engineering, this is a major change that may threaten the use of automation technologies, such as alarms and other control systems. In an article in Healthcare Packaging, Main, who is also the chairman of ANSI B11.0 machine safety standards, expressed concern that this revision may pose challenges to machine suppliers and end users in all walks of life.
"The proposed changes will make it more difficult for employers to use alternative methods because OSHA will require all energy to be shut down," Maine said in a speech at Pack Expo. "This means that new technologies or controls designed to provide safe and fast access to necessary tasks will be prohibited."