Lockout-Tagout

Ask the Expert: Alternative Control Under Lockout/Tagout

In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking what is considered alternative control under the lockout/tagout standard. See what the experts had to say.

Q: What is considered alternative control under the lockout/tagout standard?

The lockout/tagout standard allows some minor servicing operations of equipment performed during normal production operations to take place while the equipment is running and without lockout/tagout, as long as certain criteria are met including the use of what federal OSHA calls “alternative measures” that provide effective protection for the workers. The combination of these criteria and the alternative measures are collectively called the “minor servicing exception” that exempts the servicing operation from the lockout/tagout procedure.

Following are the three criteria. All must be met. Item #3 includes examples of alternative measures:

  1. The servicing activity must take place during normal production operations, while the machine or equipment is performing its intended production function.
  2. The activity must be a routine or regular course of procedure and be in accordance with established practices, repetitive or regularly repeated as part of the production process, and the activity must be essential to the production process.
  3. The entire servicing activity must use alternative measures to provide effective protection from the hazardous energy, such as specially designed tools, remote devices, interlocked barrier guards, local disconnects, or control switches which are under the exclusive control of the employee performing the minor servicing. These alternative measures must enable the employee to safely perform the servicing task without being exposed to the unexpected energization or activation of the equipment, or the release of stored energy.

See the sample minor servicing exception written plan addendum provided through the federal Centers for Disease Control and Prevention (CDC) with a concrete example how alternative measures are used (Appendix A) and guidance about verification and documentation of alternative measures at https://www.cdc.gov/nora/councils/manuf/loto/pdfs/LOTO_Minor_Servicing.pdf.