$1910\mathrm{.}147-$ The control of hazardous energy $($lockout$/$tagout$).$

The $1910\mathrm{.}147-$ The control of hazardous energy $($lockout$/$tagout$)$ covers the servicing and maintenance of machines and equipment in which the unexpected energization or start$-$up of the machines or equipment or release of stored energy could cause injury to employees. $($OSHA$,2011)$ This standard outlines the requirements of the employer to protect the worker from such an event, and it affects anyone exposed to unguarded energized equipment. This is the rule except in the following scenarios.

$$ Normal production operations would be covered under sub$-$part O machinery and machine guarding if a guard or safety device is bypassed or removed.

$$ The minor tools change exception removes normal production activities from the requirement as long as the activity is routine, repetitive, and integral to using the equipment for production $($OSHA$,2011).$

$$ Electrical equipment with a Cord and plug can be unplugged and controlled by servicing and maintenance personnel.

$$ Hot tap operations for gas, steam, water, or petroleum products are performed on pressurized pipelines where continuity of service is essential, shutting down the system is impractical, and documented procedures with special equipment to protect the employee are used.

The Letter of interpretation that was reviewed the standard regarding OSHA's Electric Power Generation, Transmission and Distribution standard, $29$ CFR $1910\mathrm{.}269.$ In this letter, the scenario of working on electric power generating facility, utilizes lockout$/$tagout $($LOTO$)$ practices in accordance with $1910\mathrm{.}269($d$).$ The plant is continually manned by operations personnel; and the operations supervisor coordinates all affected work forces to ensure continuity of protection for the crew members. When a LOTO is initiated and blocking points are selected, the shift supervisor selects a group lock box containing enough field locks to accompany the printed lockout tags. All keys for the field $($equipment$)$ locks remain in the group lock box, which is secured by the shift supervisor's individual gold lock. The supervisor's gold lock key is passed between shifts by the supervisors. Once the scope of work and blocking points are discussed with the affected work force, employees verify the LOTO blocking points and place their personal locks on the group lock box along with the shift supervisor's gold lock. When it is necessary to test or manipulate a device that is part of an existing LOTO, the facility personnel strictly follows the $[$test or positioning$]$ guidelines in $1910\mathrm{.}269($d$)(8)($i$)($A$)$ through $1910\mathrm{.}269($d$)(8)($i$)($D$).$ In addition to clearing the area, signatures of notification are obtained from all employees associated with that job, and a visual caution tag is applied to the device being tested or manipulated. Employees are tracked by documentation, computer tracking, and have access to an assigned site authorized employee for each job.

The question was asked if the shift manager can obtain the locks from the group lock box in any way they feel is fit, i$.$e$.$ bolt cutters, without the employee whom is the owner of the lock is not present in the work area but still on or near the job site. OSHA replied in saying that in a lock out program, the core basis behind it is worker protection with one lock, one key per person. The energy isolation program should have provisions for the gold key being the first one on the group lock box, last one off to open from a lock out. In no way should a lock out scenario be based off $$convenience$,$ rather should be based off worker protection.

The control of hazardous energy standard was the fourth most cited standard in $2019,$ with $2,612.($The Control of Hazardous Energy $($Lockout$/$Tagout$)1910\mathrm{.}147|2020-01-01|$ ISHN, n$.$d$.)$ in $2022,$ it was the sixth most cited standard with $2,175$ violations. $($Schiltz$,$ n$.$d$.).$ The most cited provisions were:

$1910\mathrm{.}147($c$)(4)$: Energy control procedure. $638$ violations

$1910\mathrm{.}147($c$)(7)$: Training and communication. $434$ violations

$1910\mathrm{.}147($c$)(6)$: Periodic inspection. $338$ violations

$1910\mathrm{.}147($c$)(1)$: Energy Control Program $199$ violations

Enforcement of these cited provisions could be a combination of items.

a$)$ Could be that you need to develop a program that meets or exceeds the requirements, this would be a form of abatement.

b$)$ OSHA can fine cite you and impose a fine from non$-$serious to willful. Those would depend on how their visit was to the workplace, how willing you were to cooperate with the enforcement office and if you show signs that you are taking these citations in a serious manner.

c$)$ OSHA could shut your business down until the workplace is rendered compliant.

When looking at the control of hazardous energy standards and how it would fit into a safety and health management program, that would depend on the industry for which a program is being developed. For programs that cover workers, either maintenance or operations personnel doing servicing a