Issue link: http://palletcentral.uberflip.com/i/1141207
palletcentral.com PalletCentral • May-June 2019 35 stop or redirect current flow in an electrical circuit and can be found as part of push buttons and selector switches. Often these are part of more complicated electrical or mechanical systems, but the LOTO standard applies to all electrical equipment, and also requires employers to consider issues such as stored hydraulic or pneumatic energy that can be released, as well as protecting against the hazard of accidental energizing during repair or maintenance work. The basis of OSHA's Lockout/Tagout RFI is to solicit stakeholder input from employers, workers and manufacturers, as to whether control circuit devices can properly be considered "energy isolation devices." OSHA's current LOTO standard, 29 C.F.R. 1910.147(b) defines "energy isolation device" as: A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: A manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors, and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices. Examples of "energy isolation devices" include manually operated electrical circuit breakers, disconnect switches, a line- valve, bolted blank flanges, and blocks. OSHA clearly states in the preamble to the final rule that the agency intended the LOTO standard to be performance based providing employers flexibility "to develop an effective program (procedures, training and inspections) which meets the needs of the particular workplace and the particular types of machines and equipment being maintained or serviced. However, under the existing standard, OSHA does not permit the use of control circuit devices as a means of energy isolation. Time for LOTO Revision? In the years since the 1989 Rule became effective, OSHA has received numerous questions regarding the use of control circuit devices as energy isolation devices. For example, in an April 5, 1991 Letter of Interpretation (LOI), OSHA responded to a question regarding the use of a motor starter (a control circuit device) as an energy isolation device. OSHA stated, "[t]he intent of the standard was not to include motor starter circuits within the scope of the definition of energy isolation devices" and that "such mechanisms will not be sufficient to provide the protection envisioned by the