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This information is intended to assist employers, workers, and others as they strive to improve workplace health and safety.
While we attempt to thoroughly address specific topics, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov
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• Why are we talking about this issue?
• A Brief Review of the Standard
• Amputation National Emphasis Program

www.osha.gov
1. Fall Protection
2. Hazard Communication
3. Scaffolding
4. Respiratory Protection
5. Lockout/Tagout
6. Powered Industrial Trucks
7. Electrical – Wiring Methods
8. Ladders
9. Machine Guarding
10. Electrical – General Requirements
Most frequently cited
OSHA regulations during FY 2014 inspections

1. 1910.147(c)(4)(i) (575 violations) – developing, documenting, and utilizing energy control procedures
2. 1910.147(c)(1) (508 violations) – establishing an energy control program
3. 1910.147(c)(6)(i) (431 violations) – periodic inspection of energy control procedure at least annually
4. 1910.147(c)(7)(i) (256 violations) – training on the energy control program
5. 1910.147(d)(4)(i) (172 violations) – affixing lockout or tagout devices to each energy isolating device by authorized employees

Industry Profile for 1910.147
143
109
101
97
97
84
Citations Inspections Penalty
2,671 1,550 $7,064,026
Industry Classification
Total for All Industries
509 294 $1,103,339 332 / Fabricated Metal Product Manufacturing
252
241
145
128
$910,633
$669,583
311 / Food Manufacturing
326 / Plastics and Rubber Products Manufacturing
198 120 $411,336 321 / Wood Product Manufacturing
86
61
53
61
54
45
$312,878
$183,995
$336,914
$397,838
$321,623
$244,046
333 / Machinery Manufacturing
423 / Merchant Wholesalers, Durable Goods
331 / Primary Metal Manufacturing
336 / Transportation Equipment Manufacturing
325 / Chemical Manufacturing
327 / Nonmetallic Mineral Product Manufacturing

A Few Fatal Event Descriptions
• Worker Is Killed When Caught in Conveyor
• Employee Is Killed When Caught in Grinder Drive Shaft
• Employee Is Killed When Struck By Hydraulic System
• Worker Crushes Head in Gears on Packing Machine, Later Dies
• Worker is Killed Cleaning Food Processing Machine
• Employee is Killed When Crushed Inside Machine
• Employee Falls Into Meat Processing Machine, Later Dies
• Employee Amputates Leg While Unjamming Boiler
• Employee Is Killed When Caught In Saw
• Employee Is Electrocuted While Working On Live Junction Box

Covers servicing and maintenance of machines when UNEXPECTED start-up or release of stored energy could cause injury.

– Please NOTE that control circuits (CNC’s, PLC’s, motor starters, emergency stops) ARE NOT Energy
Isolating Devices.

• During servicing and/or maintenance of machines and equipment.
• During normal production operations IF:
– A Guard or Other Safety Device is Bypassed or
Removed
OR
– A Body Part is Placed or Has the Potential to be
Placed in a Point of Operation or Other Danger
Zone

• Construction, agriculture, maritime
• Installations under exclusive control of electric utilities for power generation, transmission and distribution (1910.269(d))
• Oil and gas drilling and servicing
• Exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations (1910.333)

• Normal production operations (Subpart O –
Machine Guarding applies - 1910.212-219)
• Work on cord and plug connected equipment where plug is under exclusive control of the employee performing the servicing and/or maintenance
• Hot tap operations, under special conditions

• Note: “Minor Servicing Activities Exception:
Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by 1910.147 if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of OSHA’s
General Industry Standards).

Minor Servicing – Alternative Measures
• Shutting down the machine is not an alternative means of protection and does not protect the operator or other employees from normal production operation hazards because the machine or equipment can be easily turned on.
• Alternative means may include: interlocked barrier guards, presence sensing devices, special tools, techniques or other safeguards which are under the exclusive control of the employee.

♦ establish a program, use procedures and provide training for affixing lockout or tagout devices to energy isolating devices and to otherwise disable machines or equipment to prevent unexpected energization.

• Servicing and/or maintenance – constructing, installing, setting-up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming, making adjustments and tool changes, where employees may be exposed to unexpected energization, start-up, or release of hazardous energy.

• The employer shall establish a program consisting of
♦ an energy control procedure,
♦ employee training, and
♦ periodic inspections to ensure that, before any employee performs servicing or maintenance on machines or equipment where the unexpected energizing, start up or release of stored energy could cause injury, the machine or equipment shall be isolated from the energy source, and rendered inoperative.

• If an energy isolating device is not capable of being locked out, a tagout system shall be used.
• If an energy isolating device is capable of being locked out, lockout shall be used unless the employer can show that a tagout system provides full employee protection
(Tags Plus).

• After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such, shall be designed to accept a lockout device.

• Provided by employer
• Singularly identified
• Only devices used
• Not used for other purposes
• Durable
• Standardized
• Substantial

• Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in servicing and maintenance.
ABC Co.
Lockout Program
Purpose.___________________
__________________________
__________________________
Compliance with this program
__________________________
__________________________
__________________________
Sequence of Lockout
(1)________________________
__________________________

Lockout Procedures • Must include:
♦ Scope
♦ Purpose
♦ Authorization
♦ Rules
♦ Techniques to be utilized
♦ Means to enforce compliance
Lockout Procedures

• Procedures need to include:
♦ Specific statement of intended use of the procedure;
♦ Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control the hazardous energy;
♦ Specific procedural steps for placement, removal and transfer of lockout or tagout devices and the responsibility for them; and
♦ Specific requirements for testing a machine or equipment to determine and verify the effectiveness of the energy control measures.

• Lockout/Tagout procedures shall cover the following elements in the following sequence:
♦ Preparation for shutdown
♦ Machine/equipment shutdown
♦ Machine/equipment isolation
♦ Lockout/tagout device application
♦ Release of stored energy
♦ Verification of isolation

• Prior to restoring energy, the following procedures are required
♦ Inspect machine and equipment
♦ Safe positioning and notification of employees
♦ Removal of lockout/tagout device by authorized employee who applied the device

• Each lockout or tagout device shall be removed from each energy isolating device by the employee who applied the device.

• Specific procedures must be developed when the authorized employee is not available. The procedures must include:
» Verification that the authorized employee who applied the device is not at the facility;
» Makes all reasonable efforts to contact the authorized employee to inform him/her that his/her lockout or tagout device has been removed;
» Ensures that the authorized employee has this knowledge before he/she resumes work at that facility.

• When lockout/tagout devices must temporarily be removed for testing/ positioning:
♦ Clear machine of tools
♦ Remove employees
♦ Remove lockout/tagout device
♦ Energize and test
♦ Deenergize and reapply energy control measures

• Onsite employer and outside employer shall inform each other of their respective procedures.
• Onsite employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer’s (contractor) energy control procedures.

Group Lockout/Tagout - Additional Requirements
• Primary responsibility is vested in an authorized employee for a set number of employees.
• Authorized employee must ascertain exposure status of group members.
• If more than one crew is involved, coordinator needed.
• Each authorized employee shall use a personal lockout/tagout device and remove it when finished.

• Specific procedures needed to ensure continuity of lockout/tagout protection, including provision for the orderly transfer of lockout/tagout devices between off-going and oncoming employees.

• At least annually
• Performed by an authorized employee (other than the one(s) using procedure being inspected)
• Designed to correct deficiencies
• LOCKOUT: Must review each authorized employee’s responsibilities
• TAGOUT: Must review each authorized and affected employee’s responsibilities and additional training requirements of 1910.147(c)(7)(ii)
• Employer certification required

• Purpose and function of the energy control program are understood by employees, and that
• Employees, as a result of the training received, must have acquired the required skills and knowledge for the safe application, usage and removal of the energy controls.

• Employees shall be trained in the limitations of tags, as follows:
♦ Warning devices only
♦ Must not be removed/bypassed/ignored
♦ Must be legible and understandable
♦ Must withstand environmental conditions
♦ May evoke false sense of security
♦ Must be securely attached

• Shall be provided for all authorized and affected employees when:
♦ Change in job assignments
♦ Change in machines, equipment or processes that present new hazards
♦ Change in energy control procedures
♦ Periodic inspection reveals, or employer has reason to believe, there are deviations in employee knowledge of procedures

• The employer shall certify that employee training has been accomplished and is being kept up to date.
• The certification shall contain;
♦
Each employee’s name, and
♦
Date(s) of training

CPL 02-00-147, February 11, 2008, 136 pages

Common Pitfalls
• Failure of all exposed employees to install a lock.
• Failure to anticipate re-accumulation of energy.
• Failure to establish the specific tasks that require
LOTO.
• Failure to Lockout due to perceived feasibility issues, time constraints, … etc.
• Failure to distinguish between LOTO tasks and Minor
Servicing tasks. Failure to understand the difference.
• Failure to use an acceptable energy isolating device.

Where do we find these problems?
• Maintenance Tasks
– Relatively high rate of compliance
– Working hot is sometimes an issue due to perceived feasibility issues
• Production Tasks
– Low rate of compliance
– Machine set-up, clearing jams, tool changes, new technology

41

• Amputations NEP (CPL 03-00-019) updated
– Effective Date: Aug. 13, 2015
– Inspections to include:
• Regular operation of the machine;
• Setup/threading/preparation for regular operation of the machine;
• Clearing jams or upset conditions;
• Making running adjustments while the machine is operating;
• Cleaning of the machine;
• Oiling or greasing of the machine or machine pans;
• Scheduled/unscheduled maintenance; and
• Locking out or tagging out
42

CPL 03-00-019, August 31, 2015

• Agricultural, garden machinery, bailers
• Aerial lift platforms
• Benders, Rollers and Shapers
• Cranes (unspecified)
• Casting Machinery
• Conveyors – Belts, Chain, Live
Roller, and Auger Screw Conveyors
• Heating and cooking machinery and appliances
• Drills – Stationary
• Extruding Machinery
• Food and Beverage Processing
• Grinders, Abraders and Meat
Grinders
• Material and personnel handling machinery
• Metal, woodworking, and special material machinery
• Milling Machines
• Mowing machinery
• Mixers, Blenders, Whippers, Slicers and Food Beverage Processing
Equipment
• Packing, Wrapping, Bundling
Machinery
• Plastic Injection Molding Machines
• Press Brake (All Types)
• Presses (Mechanical, Hydraulic and
Pneumatic)
• Printing Presses
• Sawing Machinery (Band, Table,
Radial)
• Shears (All Types)

29 CFR Part 1904
Recording and Reporting Occupational
Injuries and Illnesses
45

• As of Jan. 1, 2015 there is an updated list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records.
– Previous list used the Standard Industrial Classification (SIC) system from the Bureau of Labor Statistics (BLS) from 1996-
1998.
– New list is based on North American Industrial Classification
System (NAICS) from BLS from 2007-2009.
– Retains the exemption for any establishment with ten or fewer employees, regardless of their industry classification.
46

OSHA Recordkeeping Changes (cont’d)
• Rule also added (Table 2) Industries that include establishments newly required to keep records.
47

OSHA Recordkeeping Changes (cont’d)
• Rule expands the list of severe work-related injuries and illnesses that all covered employers
must report to OSHA within 24 hours of learning about it.
– Inpatient hospitalizations of one or more employee
– All work-related amputations
– All work-related losses of an eye
• Retains the requirement to report all fatalities within 8 hours.
48

OSHA Recordkeeping Changes (cont’d)
• Amputations - The traumatic loss of a limb or other external body part.
– Amputations include a part, such as a limb or appendage, that has been severed, cut-off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; and amputations of body parts that have since been reattached.
49

Fatalities
Catastrophes
Hospitalizations
Amputation
Loss of Eye
Inspection
Category 1
390
4
849
683
2
Inspection
Category 2
12
0
903
407
0
RRI
20
3
3647
600
4
Cumulative Severe Injury Report Data through Week 37
50

Allentown Area Office
Stabler Corporate Center
3477 Corporate Parkway
Suite 120
Center Valley, PA 18034
Phone: (267) 429-7542
Philadelphia Area Office
The Wanamaker Building
100 Penn Square East
12 th Floor
Philadelphia, PA 19104
Phone: (215) 597-4955

www.osha.gov
800-321-OSHA (6742)