1.3 Authorized, affected, qualified: who you are in the standard's own words

1 Authorized, affected, and everybody else

1910.147(b) defines two roles and 1910.147(c)(7)(i) adds a third group by implication. An authorized employee is "a person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment." An affected employee is one "whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed."

The definition of authorized employee ends with a sentence that describes half the people reading this: "An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section." The operator who is expected to clear his own jams has just become an authorized employee, whether anyone has said so or not, and is owed the training in (c)(7)(i)(A).

The training splits along the same lines. (c)(7)(i)(A): authorized employees are trained in recognizing hazardous energy sources, the type and magnitude of energy available, and the methods of isolation and control. (c)(7)(i)(B): affected employees are instructed in the purpose and use of the procedure. (c)(7)(i)(C): all other employees whose work may put them in an area where energy control procedures may be used are instructed about the procedure "and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out."

2 Qualified person: a definition with three specific skills

"Qualified person" is an electrical word, and in Subpart S it has teeth. 1910.332(b)(3) says qualified persons — "those permitted to work on or near exposed energized parts" — shall at a minimum be trained in and familiar with three things: the skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment; the skills and techniques necessary to determine the nominal voltage of exposed live parts; and the clearance distances specified in 1910.333(c) with the corresponding voltages.

Note 1 to that paragraph makes it circular on purpose: "For the purposes of §§ 1910.331 through 1910.335, a person must have the training required by paragraph (b)(3) of this section in order to be considered a qualified person." There is no such thing as being generally qualified. A person can be qualified for a 480 V motor control center and unqualified at a 4,160 V switchgear in the same building, because the second one requires knowing distances and techniques the first did not.

3 Designated, competent, and the words that are not in general industry

1910.179(l)(3)(i) is short and unusually direct about overhead cranes: "Adjustments and repairs shall be done only by designated personnel." Designated means named by the employer for that task. It is the same logic as authorized, applied to a different piece of equipment by a different subpart.

"Competent person" is a construction term. It appears throughout 29 CFR 1926 — the person who can identify hazards and has authorization to take prompt corrective measures — and it does not carry the same weight in general industry, where 1910 tends to say "qualified person" or simply assign the duty to the employer. If you move between a plant and a jobsite, expect the words to change under you even though the hazard does not.

4 Where competence is required in writing

Three standards go further than "trained" and put the burden of proving competence on the employer for maintenance work specifically. They are worth knowing because they are the paragraphs an inspector reaches for after a maintenance injury.

• 1910.217(e)(3), power presses. "It shall be the responsibility of the employer to insure the original and continuing competence of personnel caring for, inspecting, and maintaining power presses." Original and continuing — a one-time class does not discharge it.
• 1910.119(j)(3), process equipment. The employer shall train each employee involved in maintaining the on-going integrity of process equipment "in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks." A mechanic on a covered process is owed process training, not just equipment training.
• 1910.147(c)(7)(iv). The employer shall certify that training has been accomplished and is being kept up to date, and the certification "shall contain each employee's name and dates of training." Two fields, both auditable.

Retraining has its own triggers in (c)(7)(iii)(A): a change in job assignment, a change in machines, equipment or processes that presents a new hazard, or a change in the energy control procedures. (B) adds retraining whenever the annual periodic inspection reveals — or the employer has reason to believe there are — deviations from or inadequacies in an employee's knowledge or use of the procedures. That second trigger is the one plants skip, because it requires admitting the inspection found something.

5 Tagout is a different job description

If your plant uses tags anywhere, you are owed more training, not less. 1910.147(c)(7)(ii) lists six limitations of tags that employees must be trained in, and they read like a warning label on the whole practice: tags are essentially warning devices and "do not provide the physical restraint on those devices that is provided by a lock"; a tag may not be removed without authorization of the person responsible for it, and is "never to be bypassed, ignored, or otherwise defeated"; tags must be legible and understandable by everyone in the area; tags and attachments must withstand the environment; tags "may evoke a false sense of security"; and tags must be attached so they cannot come off by accident.

Where lockout is used, the annual periodic inspection under (c)(6)(i)(C) includes a review between the inspector and each authorized employee of that employee's responsibilities. Where tagout is used, (c)(6)(i)(D) widens it: the review is with each authorized and affected employee, and it must cover the six tag limitations as well. The paperwork burden of tagout is deliberately heavier than lockout, because the physical protection is lighter.

6 What to ask, and when to stop

These definitions are only useful if they turn into questions you actually ask. Four are worth having ready, in this order, before a job you have not done before on a machine you do not know.

1. 1
   Am I the authorized employee for this machine, under a procedure somebody wrote for this machine — or am I being asked to improvise?
2. 2
   Does any part of this job put me on or near exposed energized parts? If yes, am I a qualified person for that voltage under 1910.332(b)(3), or does this need somebody who is?
3. 3
   Who are the affected employees, and have they been notified? 1910.147(c)(9) requires notification before the devices go on and after they come off.
4. 4
   What has changed since I was last trained on this equipment? A change in the machine or the procedure is a retraining trigger under (c)(7)(iii)(A), not a detail.

The honest answer to any of these can be "not me, not today." That is a professional answer, and it is the one the standard is built to make possible: 1910.333(c)(2) says only qualified persons may work on circuit parts that have not been deenergized, and 1910.179(l)(3)(i) says only designated personnel adjust and repair a crane. Saying you are not the person named is not a failure of nerve. It is the paragraph working.