1.4 Program, procedure and the eight-condition exception

1 A program is three things, not one

1910.147(c)(1) is the foundation paragraph and it defines the word: "The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source, and rendered inoperative."

Three legs. Remove any one and the program falls over, and every one of the three is separately citable. A plant with perfect procedures and no annual inspection is out of compliance. So is a plant with excellent training and generic procedures. The final words of (c)(1) — "isolated from the energy source, and rendered inoperative" — are the outcome all three legs exist to produce.

Note also what the paragraph does not require: a single binder called "The Lockout/Tagout Program." Nothing in the standard demands a particular document structure. What it demands is that the three components exist, work, and can be shown to work.

2 Procedures shall be developed, documented and utilized

1910.147(c)(4)(i) is one sentence: "Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section."

Three verbs, three separate failures. Developed — somebody actually walked the machine and worked out how to isolate it. Documented — it is written down. Utilized — the people doing the work use it, which means it is available at the machine and detailed enough to follow. Plenty of plants have documents that were never developed (a vendor template with the machine name pasted in) and documents that are never utilized (a binder in the maintenance office that nobody has opened since the audit).

3 The eight-condition documentation exception

Attached to (c)(4)(i) is a note that waives the written procedure for a particular machine when all of the following elements exist. Read them as a checklist where every box must be ticked:

Two things about this list are worth saying loudly. First, the exception waives the documentation, not the lockout. The machine still gets isolated, still gets locked, still gets verified. Second, condition 1 disqualifies most industrial equipment on its own. Any accumulator, any spring return, any capacitor bank in a drive, any raised member, any pneumatic circuit that holds pressure — and you are out.

In practice this exception fits a bench grinder, a drill press, a small pump on a single cord-free disconnect. It does not fit a press, a conveyor with a brake, a packaging line, a hydraulic unit, or anything with a variable frequency drive.

4 What the procedure has to contain

1910.147(c)(4)(ii) opens with a general requirement — the procedures shall clearly and specifically outline the scope, purpose, authorization, rules and techniques to be used for the control of hazardous energy, and the means to enforce compliance — and then lists four items "including, but not limited to":

1. A
   A specific statement of the intended use of the procedure.
2. B
   Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy.
3. C
   Specific procedural steps for the placement, removal and transfer of lockout or tagout devices, and the responsibility for them.
4. D
   Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices and other energy control measures.

The word "specific" appears four times in five lines. That is the drafting telling you what it wants. Item (D) in particular is the one most often reduced to the word "verify" on a form — the standard asks for the requirements for testing, meaning how you will prove, on this machine, that the isolation worked.

Part 4, Chapter 1 covers how to write each of these four sections for a real machine, and our free machine-specific LOTO procedure generator builds a document containing all four.

5 Who tells whom, and when

Two short paragraphs govern the human traffic around a lockout. 1910.147(c)(8): lockout or tagout shall be performed only by the authorized employees who are performing the servicing or maintenance. 1910.147(c)(9): affected employees shall be notified by the employer or authorized employee of the application and removal of the devices, and the notification "shall be given before the controls are applied, and after they are removed from the machine or equipment."

Before and after. Not one or the other. The first notification stops an operator from walking up mid-job and hitting start; the second stops an operator from being surprised when a machine that has been dead for six hours suddenly has power again. Step 1 of the sequence in 1910.147 Appendix A is that first notification, and the last step of restoring equipment to service is the second.

6 Hardware is the employer's job

1910.147(c)(5)(i) is easy to overlook and it matters: "Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware shall be provided by the employer for isolating, securing or blocking of machines or equipment from energy sources."

Provided by the employer. Not bought by the technician at a hardware store, not borrowed from a toolbox, not the padlock somebody had left over from a gym locker. The reason is in the next subparagraph, which Part 2, Chapter 4 covers in detail: devices have to be singularly identified, used for nothing else, standardized within the facility, substantial enough to resist removal, and marked with the identity of the employee who applied them. A random padlock fails several of those tests at once.

Put the three ideas of this chapter together and you have the shape of the rest of the course. The program is procedures plus training plus inspection. The procedure is machine-specific, documented, and built from four required elements. The hardware is standardized and provided. Everything from here is detail — but it is detail that has killed people when it was skipped.