Issue link: http://palletcentral.uberflip.com/i/1141207
38 PalletCentral • May-June 2019 palletcentral.com performance level of the control system and the most extensive error checking. Additionally, to determine the level of safety of a control system, both the IEC and the ISO standards consider the reliability of the system as a whole and its components, the operating environment, and the effects of failure. OSHA also seeks input concerning OSHA use of (or reference to) the revised consensus standard, ANSI/ASSP Z244.1—2016 The Control of Hazardous Energy Lockout, Tagout and Alternative Methods. The standard provides for decision-making flexibility regarding hazardous energy control methodology. Alternative methods, when used, are based upon risk assessment and application of the classic hazard control hierarchy. However, LOTO continues to be emphasized as the primary hazardous energy control method. ANSI Z-244.1 requires that lockout or tagout "be used unless the user can demonstrate an alternative method will provide effective protection for persons. When lockout or tagout is not used, then alternative methods shall be used only after the hazards have been assessed and risks documented." Thus, before using an alternative method, the employer is required to complete a practicability/justification analysis, a risk assessment, and other applicable evaluations. An accompanying chart and table in the ANSI standard go through the risk assessment process and the hazard control hierarchy. OSHA is seeking information, comments, and data on the effectiveness of these international consensus approaches to control system safety and any limitations or potential issues regarding their use for some tasks that currently require lockout/tagout. During the upcoming comment period, in order for industry to prevail upon OSHA that circuit control devices should be consider- ed "energy isolation devices," proponents will have to demonstrate that advancements to circuit control device technology have elimin- ated such risks as "component failure, program errors, magnetic field interference, electrical surges, etc." Additionally, proponents of circuit control devices as "energy isolation devices" will need to demonstrate their reliability (if properly maintained), and feasible means and methods that ensure they are used properly. PC SAFETY Adele L. Abrams is an attorney and safety professional who repre- sents companies in litigation with OSHA and also provides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. Adele can be reached at (301) 595-3520 or www.safety-law.com.