Recently, one of our subscribers asked the following question:
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We have a production line that oversees slicing of fish. Sometimes during the day a piece of fish gets jammed as a normal part of the production process, and we have to take it out of the slicer. The machine is electrically powered by plug and cord but the slicer is controlled by an air line. The machine is cut off, power line is disconnected , airline valve is closed (air in line releases), and lastly the guard is pulled off. The machine is controlled by a single power source and air line. Can we disconnect the two lines without lockout/tagout procedures as described in the exception to LOTO in 1910.147(a)(2)(iii)(A)? The plug is under the exclusive control of whomever is the operator.
This was our response:
The exception to lockout/tagout procedures described in Section 1910.147(a)(2)(iii)(A) applies to cord and plug connected electrical equipment only.
It does not appear from your description that your scenario meets the exception that unplugging the cord controls ALL of the hazardous energy to which the employer may be exposed. You have 2 disconnect operations that must be performed and only the electrical power source is in the control of the operator by unplugging.
According to an OSHA letter that interprets the application of 1910.147(a)(2)(iii)(A)
If the machine wiring consists of a flexible cord-connected by an attachment plug to the permanent wiring, the lockout/tagout procedure “would not apply as long as: (1) the employer unplugs the cord- and plug-connected machinery, (2) unplugging controls all of the hazardous energy to which the employee may be exposed, and (3) the plug is in the exclusive control of the employee who is performing the tool change.”
Another letter explains that the exception only applies to cord and plug connected equipment.
There is another exception to lockout/tagout procedures at 1910.147(a)(2)(ii):
“Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by [lockout/tagout] 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.”
Consider contacting your state’s free OSHA Consultative Service to help you determine if this exception applies. The service is completely separate from the enforcement arm of the agency.