4.1 Writing a procedure someone can follow

1 One procedure per machine, or per family?

1910.147(c)(4)(i) requires procedures to be developed, documented and utilized. It does not say one per machine. OSHA's standard interpretation of January 14, 2003, and its inspection directive STD 01-05-019, both accept that similar machines using the same type and magnitude of energy, with the same or similar controls, can be covered by a single written procedure — and both warn that over-generalization produces a document of little or no use to the employee who has to follow it.

The dividing line, in practice, is whether the details a technician needs are identical. Twelve identical injection moulding machines on the same feed arrangement, with the same disconnect naming convention and the same stored-energy sources, can share a procedure that names the disconnect by its position rather than its number. The same twelve machines with three different drive retrofits and two hydraulic arrangements cannot.

2 The four required elements, written out

1910.147(c)(4)(ii) requires the procedure to clearly and specifically outline the scope, purpose, authorization, rules and techniques for controlling hazardous energy, and the means to enforce compliance — including four named items. Here is what each one looks like when it is written properly.

1. A
   Intended use. "This procedure applies to servicing and maintenance of Press 4 (asset 10412), Building B bay 3. It does not cover die changes performed under the alternative-measures procedure AM-07."
2. B
   Shutdown, isolation, blocking, securing. The numbered steps, with the identifier and physical location of every isolating device and every block.
3. C
   Placement, removal and transfer of devices, and responsibility. Who applies what, where the group lockbox lives, what happens at shift change, and what happens if someone leaves with their lock on.
4. D
   Testing requirements to verify effectiveness. What is tested, how, and what reading or observation proves it.

The word "specific" appears in three of those four subparagraphs. The document that results is longer than a generic template and shorter than a manual — usually one or two pages for a real machine.

3 Borrowing the shape of Appendix A

1910.147 Appendix A is non-mandatory, and its own opening paragraph says so: it is provided to assist employers in developing their procedures so they meet the requirements of the standard, and for more complex systems more comprehensive procedures may need to be developed. But its structure is a gift, because it is OSHA's own idea of what a minimum procedure looks like, complete with the blanks it expects you to fill.

The blanks are the interesting part. Appendix A leaves lines for: the name of the company or the identification of the equipment; the type of compliance enforcement for violations; the names and job titles of affected employees and how to notify them; the types and magnitudes of energy, its hazards and control methods; the types and locations of machine operating controls; the types and locations of energy isolating devices; the types of stored energy and the methods to dissipate or restrain it; and the method of verifying isolation.

Read that list as a specification. Every blank is a thing OSHA expects a written procedure to answer for a specific machine, and a document with eight filled-in blanks satisfies (c)(4)(ii) far more convincingly than three pages of general prose.

4 Writing steps someone can follow under pressure

Four habits separate a procedure that gets used from one that gets filed.

Two more rules of style. Use one action per numbered step, so a step cannot be half-done. And write in the imperative — "Close V-114 and apply chain lockout" — rather than in the passive, so the reader always knows whether they are being told something or asked to do something.

5 Where the procedure lives, and how it stays true

"Utilized," the third verb of 1910.147(c)(4)(i), is a requirement about availability as much as about behaviour. A procedure in a binder in an office two buildings away is not used; a laminated copy in a holder at the machine, or a tablet with the current revision, is.

Keeping it true is a matter of two triggers. The first is change: 1910.147(c)(7)(iii)(A) requires retraining when machines, equipment or processes change so as to present a new hazard, or when the energy control procedures change — which presupposes that the procedure was updated when the machine was. Build the LOTO procedure into whatever sign-off your plant uses for equipment modifications and the update happens by default.

The second trigger is the annual periodic inspection under 1910.147(c)(6)(i), covered in Chapter 3 of this part. It is performed by an authorized employee other than the ones using the procedure, and (c)(6)(i)(B) requires it to correct any deviations or inadequacies identified. In practice that is the yearly audit that catches the disconnect that was renumbered and the valve that moved.

6 A review checklist for any procedure

Hand somebody else's procedure to a technician who has never serviced that machine and ask them to walk it. If any of these questions gets a shrug, the document is not finished.