Oregon OSHA Health and Safety

RESOURCE

October 2015

Understanding the three critical components of an energy control program

by Ellis Brasch

Every year since 2008, The control of hazardous energy (1910.147) has been one of Oregon OSHA's 10 most violated standards. Also known as the lockout/tagout standard, 1910.147 covers the safety requirements for employees who perform service and maintenance work on equipment that could unexpectedly start up or release hazardous energy.

What keeps 1910.147 in the top 10 list are the violations that come from just one part of the standard: 1910.147(c) – most of which have been rated "serious" every year since 2011.

What is it about 1910.147(c) that leaves many employers out of compliance? There are three critical components to any energy control program and the requirements for those components are all in 1910.147(c). Most of the violations and many accidents involving hazardous energy happen because one or more of those components were missing or employers did not enforce them. Those components include:

Are they part of your energy control program?

Document energy control procedures

If you have employees who perform service or maintenance work on equipment that could start up unexpectedly, they must follow specific procedures that will ensure the equipment is safe when they are doing the work. The procedures must describe:

The procedures should also describe how to temporarily remove locks or tags if it is necessary to energize equipment for testing, and how to reenergize equipment when the work is done.

Is it necessary to have a separate procedure for each piece of equipment? Not necessarily. Similar equipment can be covered by one procedure when the equipment:

To learn more about hazardous energy and how to control it, see Lockout/Tagout: Oregon OSHA's guide to controlling hazardous energy.

Train all employees about hazardous energy

Make sure that your employees know basic hazardous-energy concepts and the purpose of the devices used to control hazardous energy. They should also know what tasks might expose them to hazardous energy and that they are not allowed to restart equipment that is locked out or tagged out. Authorized employees and affected employees need additional training.

Authorized employees - Those who service equipment. They must know how to find and recognize hazardous energy sources, how to identify and find the types and magnitudes of the energy sources in their workplace, and how to isolate and control the energy sources.

Affected employees - Those who operate equipment or work in areas where the equipment is serviced. They must understand the purpose of energy control procedures and how they are used.

Keep current training records for each authorized and affected employee that includes the employee's name and training date.

Retrain employees when there are changes in the workplace that could introduce new hazards, such as jobs, the energy control procedures, the equipment, or work processes. Employees must also be retrained when they do not follow established energy control procedures.

Inspect the procedures at least annually

Annual inspections ensure that the procedures are effective and that your employees are correctly using them. An authorized employee must inspect each energy control procedure at least once each year. The inspection can be scheduled or done randomly; the authorized person who does the inspection must understand the procedure and must not be among those who are using the procedure at the time of the inspection.

A successful inspection confirms that:

  • The procedure is accurate
  • The procedure is being followed
  • The procedure addresses all energy sources
  • Employees understand the procedure
  • Employees understand their responsibilities for controlling hazardous energy.

When the inspection shows that employees are not following the procedure or that the procedure is not protecting them, you must take corrective action, which might include:

  • Revising the procedure
  • Acquiring additional lockout or tagout devices
  • Providing additional employee training
  • Increasing supervision over employees who use energy control procedures

The inspection must also be "certified" to show that it has been completed. The certification identifies the equipment, the inspection date, the employees included in the inspection, and the inspector.

If you want to receive the Resource Newsletter, sign up for future issues here.

Reprinting, excerpting, or plagiarizing any part of this publication is fine with us. Please send us a copy of your publication or inform the Resource editor as a courtesy. If you have questions about the information in Resource, please call 503-378-3272.

For general information, technical answers, or information about Oregon OSHA services, please call 503-378-3272 or toll-free within Oregon, 800-922-2689.