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STEELTOETOOLS
Part 113 min

1.4 The pre-job walk: what to know before you touch anything

1910.147(d)(1) is the only step in the sequence that happens before you touch the machine, and it is the one most often skipped: "Before an authorized or affected employee turns off a machine or equipment, the authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy." Knowledge, in advance, of three specific things. This chapter is about how you actually get them in the ten minutes before a job.

1 Type, magnitude, hazard, method

Take (d)(1) apart. Type is which of the energies from Chapter 2 are present. Magnitude is the number — 480 volts, 2,500 psi, 350 °F, 1,800 pounds of ram. Hazards is what that number does to a person. Method or means is the specific device you are going to operate and the specific block you are going to set.

Magnitude is the one people leave out, and it is the one that decides your PPE, your tools and your test instrument. 1910.334(c)(3) puts it plainly for meters: "Test instruments and equipment and their accessories shall be rated for the circuits and equipment to which they will be connected and shall be designed for the environment in which they will be used." You cannot pick a correctly rated instrument for a voltage you have not established.

Type — which energies are present
Magnitude — the actual numbers
Hazard — what it does to a person
Method — the device and the block

2 Read the procedure against the machine, not instead of it

1910.147(c)(4)(ii) says what a written procedure has to contain, and the fourth item is the one to check first: "Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures." A procedure that tells you which breaker to open but not how to prove the machine is dead has skipped the step that keeps you alive.

The way to read a procedure is with it in your hand, standing at the machine, touching each device it names. A procedure written three years ago describes a machine that has since had a drive replaced, an accessory added on a cord, a valve relocated during a shutdown, and a panel relabeled by somebody in a hurry. Every one of those is a difference between the paper and the steel, and finding it is your job before it is anybody else's.

Common mistake: trusting the panel legend. 1910.303(f)(1) requires each disconnecting means for motors and appliances to be "legibly marked to indicate its purpose, unless located and arranged so the purpose is evident," and (f)(2) says the same for each service, feeder and branch circuit. It is a real requirement and it is also one of the most commonly stale pieces of information in any plant. A label is a starting hypothesis; the test in Part 2, Chapter 3 is the answer.

3 The hazard assessment you are owed, and the PPE that follows

1910.132(d)(1) requires the employer to assess the workplace to determine whether hazards are present that necessitate PPE and then to select PPE that protects against the hazards identified, communicate those decisions to each affected employee, and select PPE that properly fits each employee. (d)(2) requires that assessment to be verified "through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment."

For maintenance work the assessment has an awkward feature: the hazards change task by task on the same machine. Welding a guard bracket, breaking a hydraulic fitting and pulling a motor out of a wet pit are three different PPE problems in one work order. A per-machine assessment that never names the task is not much use, and the fix is to run the task-level thinking yourself, before the job, with the same four categories the standard uses.

One rule with no exceptions: 1910.132(e), "Defective or damaged personal protective equipment shall not be used." Nine words, and they cover the cracked face shield in the shop drawer as surely as the harness with a broken stitch.

4 The physical walk: five things you can see

Some of the pre-job check is nothing but looking, and it maps onto specific paragraphs. Do it in the order the job will happen — approach, workspace, machine, above, below.

  • The approach and the floor. 1910.22(a)(3) requires walking-working surfaces to be maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow and ice — and a maintenance job creates most of those before it is over. 1910.22(c) requires a safe means of access and egress to and from the surface you will be standing on.
  • The electrical working space. 1910.303(g)(1)(i) sets the depth of clear working space in front of equipment likely to be examined, adjusted, serviced or maintained while energized, and Table S-1 gives 3 ft at 0 to 150 volts to ground, and at 151 to 600 volts 3 ft, 3.5 ft or 4 ft depending on whether the far side has no live or grounded parts, grounded parts, or live parts with you between them. (g)(1)(ii) is blunt: that space "may not be used for storage."
  • The width and the door swing. (g)(1)(i)(B) requires the working space to be the width of the equipment or 30 in., whichever is greater, and "in all cases, the working space shall permit at least a 90-degree opening of equipment doors or hinged panels."
  • Light. (g)(1)(v) requires illumination for all working spaces about service equipment, switchboards, panelboards and motor control centers installed indoors, and adds that in electric equipment rooms the illumination "may not be controlled by automatic means only." An occupancy sensor that times out with your head in a panel is a defect, not a feature.
  • What is over you and under you. Anything raised, stored on a mezzanine, hanging from a hoist or sitting on top of the machine is a struck-by hazard for the duration of the job — and a floor hole opened to run conduit is a fall hazard the moment the cover comes off. Part 4, Chapter 1 covers both.
On the job: the three-foot rule in Table S-1 is measured "from the live parts if they are exposed or from the enclosure front or opening if they are enclosed" — so a pallet of product parked 30 in. from an MCC door is a violation before you arrive and a hazard the second you open it. Moving it is part of the job, not somebody else's problem.

5 Talk to production before you take the machine

Two paragraphs make this a requirement rather than a courtesy. 1910.147(d)(2) requires the machine to be turned off using the procedures established for it, and adds: "An orderly shutdown must be utilized to avoid any additional or increased hazard(s) to employees as a result of the equipment stoppage." Stopping a machine mid-cycle can leave product in a die, material in an oven, a slug in a chute or a full vessel with no downstream flow — each of which is a hazard you created by shutting down badly.

And 1910.147(c)(9) requires that affected employees be notified by the employer or the authorized employee of the application and the removal of lockout or tagout devices, with notification "given before the controls are applied, and after they are removed from the machine or equipment." Two notifications, in that order, every time.

In a plant covered by 1910.119, the same conversation is formalized: (f)(4) requires safe work practices for "control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel," and (f)(1)(i)(G) requires an operating procedure for "startup following a turnaround" — which is the moment your work becomes production's problem.

6 A pre-job walk that fits on one page

Nothing here is exotic, and none of it takes long once it is a habit. What it replaces is the most common opening move in maintenance work: walking up with a tool bag and starting.

  1. 1
    Get the procedure for this machine and read it standing at the machine, touching every device it names. Note every difference between the paper and the steel before you operate anything.
  2. 2
    Write down the magnitudes: volts, psi, temperature, weight. They select your instrument, your PPE and your blocking.
  3. 3
    Walk the energy paths, not the disconnects. Ask what is above you, what is behind the wall, and what shares a power unit with this machine.
  4. 4
    Clear and light the working space — Table S-1 depth, 30 in. or the equipment width, a 90-degree door swing, and light that will not switch itself off.
  5. 5
    Agree the shutdown with production so it is orderly under (d)(2), and make sure affected employees are notified under (c)(9) before anything is applied.
  6. 6
    Decide out loud what would make you stop: a device that will not lock, an energy the procedure does not name, a voltage you are not qualified for. Deciding after your hands are in the machine is too late.
Key takeaways
  • 1910.147(d)(1) requires knowledge of the type and magnitude of the energy, its hazards, and the method of control before the machine is turned off.
  • A written procedure must include specific requirements for testing to verify the effectiveness of the energy control measures — 1910.147(c)(4)(ii)(D). One without them is incomplete.
  • Panel and disconnect labels are required by 1910.303(f)(1) and (f)(2) and are also among the stalest data in any plant. Treat a label as a hypothesis, not a verification.
  • Table S-1 in 1910.303(g)(1) gives 3 ft of clear working depth at 0 to 150 V, and 3, 3.5 or 4 ft at 151 to 600 V by condition — and (g)(1)(ii) forbids using that space for storage.
  • 1910.147(d)(2) requires an orderly shutdown so that stopping the machine does not create a new hazard, and (c)(9) requires affected employees to be notified before application and after removal.
  • 1910.132(d) entitles you to a hazard assessment with a written certification, and 1910.132(e) forbids the use of defective or damaged PPE with no exception.

Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.