If your company requires the servicing and maintenance of machines and/or equipment in which the unexpected energization could release stored energy, then controls must be established to protect the employees performing the work, as well as others in the vicinity, from that hazardous energy. This is a regulatory requirement that is covered under the Occupational Safety and Health Administration (OSHA) standard 29 CFR 1910.147 (c)(1). However, accomplishing this task is often easier said than done. Developing an effective energy control program requires an understanding of Lockout/Tagout (LOTO), attention to detail, available resources, and continual review of the program.

As per OSHA’s requirement, an energy control program must consist of energy control procedures for the affected machines and/or equipment, authorized and affected employee training, and periodic inspections of the Lockout/Tagout process to ensure that hazardous energy is isolated and rendered inoperative before being serviced or maintained. 

How can I maintain OSHA compliance?

1. Complete an inventory of all machines and/or equipment on-site that may require servicing and maintenance.  Such an inventory will include the types and number of energy sources namely electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources that can be hazardous to employees. All hazardous energy sources must be accounted for.

2. Consistently label all hazardous energy sources accordingly so that they are easily identified during the Lockout/Tagout process. It is important that the different energy sources are not confused with one another.

3. Clearly label all control points correctly so that they are easily identified during the Lockout/Tagout process. Also, ensure that the control points are accessible.

4. Develop energy control procedures utilizing Lockout/Tagout for each piece of machinery and/or equipment that may be serviced or maintained. Ensure that each procedure has instructions for both de-energization and re-energization.

   • De-energization should include the following steps:

     • Notify affected employees regarding de-energization

     • Review machine and/or equipment specific procedure

     • Shut down machinery and/or equipment

     • Isolate hazardous energy source

     • Lockout/Tagout hazardous energy source

     • Dissipate any stored energy

     • Verify isolation and de-energization of machinery and/or equipment

   • Re-energization should include the following steps:

     • Inspect the immediate work area

     • Clear personnel from the immediate work area

     • Verify that controls are not engaged

     • Lockout/Tagout removal

     • Notify affected employees regarding re-energization

5. Maintain electronic copies of procedures and post hard copies on machines and/or equipment for easy reference.

6. Develop training for authorized and affected employees. Provide the necessary training initially, then additionally whenever machines and/or equipment change, if energy control procedures are revised, and when employee responsibilities are adjusted.

7. Complete annual periodic inspections of the energy control procedures to ensure that they and the standard are being complied with. The inspections must follow these guidelines:

   • Must be performed by an authorized employee to correct any deviations identified

   • Must include a review between the inspector and each authorized and affected employee that falls under the energy control procedure being inspected

   • Must certify that the periodic inspections were completed by documenting the identity of the machine and/or equipment, the date, the employee or employees included in the inspection, and the inspector

Do not be overwhelmed by the size of your facility, the number of machines and/or equipment on-site, or the lack of time and resources available. KERAMIDA has experienced safety professionals who can assist you with the development of a comprehensive energy control program that is effective in keeping your employees safe and maintaining compliance with the OSHA standard. Fill out our quick response form or call (800) 508-8034 to speak with one of our professionals today.

Blog Author

Andrew Tirmenstein
Senior Project Manager, Security, Health and Safety Services
ISO 45001 & ISO 14001 Auditor
KERAMIDA Inc.

Contact Andrew at atirmenstein@keramida.com.