als to establish the hazardous energy control procedures. These manuals and materials often provide specific step-by-step instructions on how to safely perform servicing or maintenance tasks. For example, the removal of an ignition key is not sufficient to protect employees from devices that may operate or activate independently of the ignition system. That is why it may be necessary to disconnect the battery cable for some repair tasks, such as working on some cooling fans, which automatically start up even after the key has been removed. Likewise, air bags may inadvertently deploy and cause employee injury if the system is not properly controlled and residual energy dissipated before servicing or maintenance begins. Employers, who meet manufacturers’ servicing and maintenance guidelines, may be cited for a §1910.147 violation if the manufacturer guidelines inadequately control the vehicle’s energy sources and employee exposure exists to hazardous energy.
Troubleshooting, Testing, and Component Positioning There are circumstances when it is necessary to re-energize the vehicle or a component to accomplish a particular task (e.g., diagnostic testing; maintenance troubleshooting; vehicle or component positioning). OSHA does allow energization for testing or positioning purposes, as specified in §1910.147(f)(1), but only
for the limited time during which it is necessary to test or reposition the vehicle or component. During these transition periods, employee exposure to hazards is high and a procedure needs to be developed to define the sequence of actions to accomplish the task safely. Under no circumstances is any part of an employee’s body ever permitted to be exposed within a hazardous area, such as the point-of-operation or in-going nip point area, during servicing and/or maintenance activities while the machine is running or energized. The use of supplemental safeguarding actions, such as personal protective equipment to protect against hot surfaces, use of a tarp to shield a hot surface or in-going nip point, safe work positioning, etc., must be used in conjunction with established procedures to protect your employees
Working Safely OSHA requires employers to develop LOTO procedures and to have workers follow them. If you cut corners on these procedures, the result is likely to be equipment downtime, accidents, OSHA inspections and citations, and, possibly, employee fatalities. TOW Copyright 2013 J. J. Keller & Associates, Inc.+, P.O. Box 368, 3003 Breezewood Lane, Neenah, WI 54957
www.towprofessional.com | Volume 2 • Issue 8 | Tow Professional
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