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Battle for the Control of Hazardous Energy: The Tortured Conflicts and Impacts of ANSI Z244.1 and OSHA’s 29 CFR 1910.147

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The Battle for the Control of Hazardous Energy: The Tortured Conflicts and Impacts of ANSI Z244.1 and OSHA’s 29 CFR 1910.147


By Bruce W. Main, PE CSP, and Ed V. Grund, PE CSP


The current requirements for the control of hazardous energy appear at 29 CFR 1910.147, The control of hazardous energy (lockout/tagout) under OSHA, and in the industry consensus standard ANSI/ASSE Z244.1, The Control of Hazardous Energy: Lockout, Tagout and Alternative Methods. Unfortunately, significant differences between the requirements in these documents have created confusion as to how employers should effectively control hazardous energy to protect employees. 


The Battle for Control of Hazardous Energy:

 

  • assists readers in understanding the differences between OSHA’s requirements for the control of hazardous energy and industry’s understanding and application of these requirements; and
  • educates readers on the industry-accepted standard of care, alternative methods, and risk assessment, as contained in Z244.1.



The history of the developments related to both the ANSI Z244.1 and OSHA’s 29 CFR 1910.147 requirements are discussed, as well as a comparison of the content of OSHA 29 CFR 1910.147 with the 
the 1982, 2003 and 2016 versions of ANSI Z244.1. An extensive analysis of the industry and OSHA standards highlights the practical implications of OSHA’s interpretations and positions related to the control of hazardous energy; in particular, a detailed examination of OSHA’s service and maintenance construct. 


A summary of key legal cases related to 29 CFR 1910.147 highlights decisions made by the courts and the implications thereof. Potential solutions to the problems identified from the analyses and the current situation between OSHA and industry are explored.


The international activity on the control of hazardous energy is also considered through standards developed in Canada and in ISO (international). 


The Battle for Control of Hazardous Energy is written to assist employers and engineers to design workplaces, equipment, and procedures such that employees will be protected from the unexpected release of hazardous energy, and to achieve a workplace where risks have been reduced to an acceptable level.

 
 

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