OSHA Offers Clarification on Control of Potentially Hazardous Energy

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In response to a letter from the ANSI/ASSE Z244.1 (control of potentially hazardous energy) Accredited Standards Committee (ASC) seeking clarification on lockout/tagout and the use of alternative control methods, OSHA indicates that if an OSHA standard provides a requisite level of employee protection, employers may not adopt an alternative approach that provides a lesser level of protection.

Furthermore, upon request from the Z244.1 Committee for OSHA to adopt the Z244.1-2016 consensus standard, OSHA has indicated that it plans to issue a request for information (RFI) to collect information on modernizing and updating its own 29 CFR 1910.147 standard on Control of Hazardous Energy. The current timeline for issuance of the RFI is April 2018.

“This response demonstrates that the functional protection expected by OSHA has its focus on the assured prevention of sudden start up or other release of hazardous energy that could harm workers,” says Todd Grover, global senior manager, Applied Safety Solutions at Master Lock Co. and ANSI Z244.1 committee member. “Lockout/tagout can do this as an administrative control if the energy sources are fully understood, procedural guidance is correctly applied and sufficiently trained workers are provided the time and lockout equipment to fully control their exposure.”

This letter represents the latest chapter in a long and complex history between these two standards. For decades, ANSI/ASSE Z244.1 and OSHA’s 29 CFR 1910.147 have stood as the industry and government standards, respectively, for the control of potentially hazardous energy. While these documents share the same goal of protecting workers, they are still not aligned in the methods by which that can be achieved.

Control of potentially hazardous energy has and continues to be an issue of great importance to the OSH community. In fiscal year 2016, lockout was ranked as the fifth most common cause of citations among OSHA’s top 10. This underscores the need for OSH professionals to have a comprehensive understanding of both the ANSI/ASSE and OSHA standards in order to protect those doing potentially hazardous work.

To help OSH professionals better understand this complex issue, ASSE’s upcoming webinar, ANSI/ASSE Z244.1: The Control of Hazardous Energy Lockout, Tagout and Alternative Methods, will discuss the relationship between Z244.1 and 29 CFR 1910.147, the structure and content of Z244.1, when to use alternative methods for hazardous energy control and much more.

In addition, ASSE has developed an issue analysis that links to the OSHA letter of interpretation regarding ANSI/ASSE Z244, as well as another letter regarding ANSI/ASSE Z359; and a legal opinion on these developments from the Law Office of Adele L. Abrams PC. Download it here.


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