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Employers often write to OSHA asking for clarifications of its requirements. Sometimes, OSHA writes back. Although the guidance requested is sometimes so specific it cannot apply to other employers, in some situations, OSHA’s advice can be useful for many employers—as in the case of today’s set of questions.
Authorized Employees Servicing Cord-and-Plug-Connected Equipment
An employer wrote to OSHA asking whether an employee performing servicing or maintenance on cord-and-plug-connected electric equipment under the exception found in 29 CFR 1910.147(a)(2)(iii)(A) must be an “authorized employee” under the standard.
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OSHA’s interpretation: No. As long as the method of isolating the energy to the equipment is limited to unplugging the equipment and maintaining control of the plug, §1910.147 does not require an employee who performs maintenance on cord-and-plug-connected equipment to be an “authorized employee.”
‘Single Energy Source’ vs. ‘Plug-and-Cord Connected’
An employer wrote to OSHA asking about a worker performing maintenance on a single piece of shop machinery, such as a lath or drill press, that has a single energy source with a disconnect switch located in clear view, within 5 unobstructed feet of the machine, on an adjacent wall. If a worker places the disconnect switch in the “off” position, removes the fuses from the disconnect switch and the machine’s control panel, and verifies that the machine will not start, and if another employee would have to walk past that employee to reach the disconnect switch, is the disconnect switch “under the exclusive control” of the employee performing the maintenance, and is the employee still required to place a lockout or tagout device on the disconnect switch
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OSHA’s interpretation: Yes. The exception found at Section 1910.147(a)(2)(iii)(A) specifies that it applies to cord-and-plug-connected equipment only. It does not apply to other forms of energy-isolation devices, such as a disconnect switch. The disconnect switch described in the scenario above would have to be locked out.
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