Issue link: http://palletcentral.uberflip.com/i/1141207
n May 17, 2019, OSHA issued a request for information (RFI) seeking comments on the use of control circuit-type devices to isolate energy, as part of future modifi- cations to the agency's "Lockout/ Tagout" (LOTO) standard. The RFI also seeks comments regarding evolving technology involving robotics and data about any new risks of exposure to hazardous energy that employees may face as a result of increased interaction with robots, as well as any reduction in risks or other benefits to worker safety, associated with using robots. Comments to OSHA's RFI are due on or before August 19, 2019. The link with all information, including the platform for electronically submitting comments, is http://bit.ly/2ZpyZck. Comments should reference OSHA Docket #OSHA-2016-0013- 0001. Basics OSHA's Lockout/Tagout final rule, 29 CFR 1910.147, became effective September 1, 1989, and is one of the most often cited standards in the pallet manufacturing sector. Overall, it is OSHA's fifth most cited rule, with nearly 3,000 citations issued under this standard in FY 2018. Since 2008, OSHA has had specific enforce- ment guidance for this standard available in CPL 02-00-147, http://bit.ly/2F9NqK2. In addition, this standard is often cited as part of OSHA's National Emphasis Program on Amputation Prevention for general industry. That NEP, which was scheduled to expire on August 13, 2018, has been extended through September 30, 2019. The Lockout/Tagout standard requires employers to develop and utilize standardized procedures for the control of potentially hazardous energy (e.g. electrical, pneumatic, steam, chemical, gravity, etc.) during servicing and maintenance of machines or equipment. The intent of the standard is to prevent the unexpected energization or start-up of machines or equipment. Employers must also observe and document the evaluation of representative employees performing LOTO by following the written procedures on an annual basis. The LOTO rule recognizes that some activities, which are classified as servicing or maintenance, but that are frequently performed during normal production operations (e.g. lubricating, cleaning, unjamming, minor adjustments and simple tool changes), do not require the application of lockout/tagout so long as "the activity is performed using alternative measures which the employer can demonstrated are equally effective." Such "alternative measures" include control circuit devices (other "alternative measures" include control equipment and operating procedures). Control circuit devices are used to "turn on" or "turn off " current flow in an electrical circuit. Control circuit devices include a variety of switches, relays, and solenoids, and are needed to start, 34 PalletCentral • May-June 2019 palletcentral.com O SAFETY OSHA Issues RFI on Lockout/Tagout Standard Update By Adele L. Abrams, Esq., CMSP and Brian S. Yellin, Esq., CIH, CSP iStockphoto.com/JIRAROJ PRADITCHAROENKUL