3.4 When the machine has to run: testing and positioning

1 The five actions, and what they add up to

1910.147(f)(1) applies to "situations in which lockout or tagout devices must be temporarily removed from the energy isolating device and the machine or equipment energized to test or position the machine, equipment or component thereof," and requires this sequence:

1. 1
   (i) Clear the machine or equipment of tools and materials in accordance with paragraph (e)(1) — the work area inspected to ensure nonessential items are removed and machine components are operationally intact.
2. 2
   (ii) Remove employees from the machine or equipment area in accordance with paragraph (e)(2) — the area checked so that all employees are safely positioned or removed.
3. 3
   (iii) Remove the lockout or tagout devices as specified in paragraph (e)(3) — each device removed by the employee who applied it.
4. 4
   (iv) Energize and proceed with testing or positioning.
5. 5
   (v) Deenergize all systems and reapply energy control measures in accordance with paragraph (d) to continue the servicing or maintenance.

Read together, the five actions describe a complete release and a complete re-lockout, compressed. Step (v) points back at the whole of paragraph (d), which means the six steps of Part 2 run again from the top — including verification. There is no version of (f)(1) in which somebody remains inside the machine, and no version in which the locks stay off "while we sort this out."

2 The two shortcuts, and what each one costs

The first shortcut is the inch button — running the machine from a jog or teach control while somebody is inside it. The definition in 1910.147(b) is what forecloses it: push buttons and selector switches are not energy isolating devices, so a machine being jogged is an energized machine, not a controlled one. The protection during a jog is not the button; it is the fact that nobody is exposed, which is exactly what (f)(1)(ii) requires you to establish first.

The second shortcut is leaving the locks off between tests, because the job needs four cycles and re-locking each time feels absurd. What that produces is a machine that spends the whole job energized, with a crew that has stopped tracking who is where. Where a job genuinely needs repeated cycling with people close by, the answer is an engineered one — a hold-to-run control with the operator outside the hazard, an enabling device, a guard that permits observation without access — and choosing it is engineering work, not a field decision.

On the electrical side there is a parallel sentence with the same force. 1910.333(b)(2)(v) requires its four reenergizing steps to be met "before circuits or equipment are reenergized, even temporarily." Even temporarily. A quick bump to check rotation is a reenergization, and it needs the visual determination that all employees are clear.

3 Power presses: die setting and the weekly test

1910.217 is the most demanding machine standard in Subpart O, and two of its paragraphs are pure maintenance. (e)(1) requires an inspection program "having a general component and a directed component," and the two components ask for different things.

Under the general component, (e)(1)(i)(A) requires periodic and regular inspections of each power press "to ensure that all of its parts, auxiliary equipment, and safeguards, including the clutch/brake mechanism, antirepeat feature, and single-stroke mechanism, are in a safe operating condition and adjustment"; (B) requires necessary maintenance or repair to be performed and completed before operating the press; and (C) requires a certification record of each inspection and each maintenance and repair task, containing the date, the signature of the person who performed the work, and the serial number or other identifier of the press.

Under the directed component, (e)(1)(ii)(A) is the one with the interval: "Inspect and test each press on a regular basis at least once a week to determine the condition of the clutch/brake mechanism, antirepeat feature, and single-stroke mechanism." (B) requires the maintenance or repair on those three to be completed before operating the press, and (C) requires a certification record of each maintenance task performed under the directed component with the date, the signature and the press identifier.

Two more from the same paragraph. (e)(2): "It shall be the responsibility of any person modifying a power press to furnish instructions with the modification to establish new or changed guidelines for use and care of the power press so modified." If you modify it, you own the documentation for the modification — a rule Part 5, Chapter 4 generalizes. And (e)(3): the employer is responsible for "the original and continuing competence of personnel caring for, inspecting, and maintaining power presses."

4 Cranes and hoists: the five precautions before a repair

1910.179(l)(2)(i) lists what has to happen before adjustments and repairs are started on an overhead or gantry crane, and it is the most concrete pre-repair checklist in Subpart N. It is written for cranes and it transfers cleanly to any machine that shares a track, an aisle or a service with something else that moves.

• (a) The crane to be repaired shall be run to a location where it will cause the least interference with other cranes and operations in the area.
• (b) All controllers shall be at the off position.
• (c) The main or emergency switch shall be open and locked in the open position.
• (d) Warning or "out of order" signs shall be placed on the crane, "also on the floor beneath or on the hook where visible from the floor."
• (e) Where other cranes are in operation on the same runway, rail stops or other suitable means shall be provided to prevent interference with the idle crane.

Item (e) is the one with no counterpart in 1910.147: a physical stop to keep a different machine from reaching the one you are working on. On a shared runway, a shared conveyor line or a common transfer, ask the same question — what else can arrive here while I am in it?

And the inspection framework in (j) is worth knowing because it is where a maintenance department's real numbers live. (j)(1)(ii) splits inspection into "frequent" — daily to monthly intervals — and "periodic" — one to twelve month intervals. (j)(2)(iii) requires hooks to be visually inspected daily, with a monthly inspection carrying a certification record that includes the date, the signature of the inspector and the serial number or other identifier of the hook; hooks with cracks, or "more than 15 percent in excess of normal throat opening or more than 10° twist from the plane of the unbent hook," go to the discard rule in (l)(3)(iii)(a). Running ropes get a thorough inspection at least once a month with the same certification record, under (m)(1). Test loads under (k)(2) "shall not be more than 125 percent of the rated load unless otherwise recommended by the manufacturer."

1910.179(l)(3)(iii)(a) also states the repair philosophy for a hook, and it is one worth carrying to other components: a hook showing those defects "shall be discarded. Repairs by welding or reshaping are not generally recommended." Where such a repair is attempted, it must be under competent supervision and the hook must be tested to the (k)(2) load before further use.

5 Forklifts and mobile equipment in the shop

1910.178(q) is a compact set of rules for maintaining powered industrial trucks, and several of them apply to any mobile equipment a maintenance department services.

Paragraphs (q)(5) and (q)(6) are the return-to-service rules in miniature — equivalent parts, no alterations — and they are the reason Part 5, Chapter 4 spends its time on what counts as a change. Paragraph (q)(10) is a solvent rule with a real number in it, and it is a good default for any shop: below 100 °F flash point, find something else.

6 Deciding, before the job, when the machine will run

Every maintenance job has one of three shapes, and knowing which one you are in before you start is what keeps (f)(1) from becoming an improvisation.

1. 1
   Fully dead for the whole job. Lock, block, verify, work, release. Most repairs are this, and the discipline is simply not to let it drift into shape two.
2. 2
   Dead, with planned energized intervals. The job needs motion at known points — alignment, timing, a proof run. Each interval is a full (f)(1) cycle, planned in advance, with a named person clearing the machine and nobody inside it.
3. 3
   Genuinely energized work. Rare, and it needs a demonstration under 1910.333(a)(1) that deenergizing introduces additional hazards or is infeasible, a qualified person under (c)(2), and the arc flash controls that live in NFPA 70E. If nobody can produce that demonstration, the job is shape one or two.

The target lift fatality in Part 1 was a shape-one job that drifted. The machine was "requested to be offline," bolts were being tightened by hand — nothing about it needed motion — and the arms came down anyway (OSHA Accident Summary Nr 174972.015). The whole value of naming the shape out loud is that it makes the drift visible while there is still time.