ABA, as part of the Coalition for Workplace Safety and as an individual association, responded to the Occupational Safety & Health Administration (OSHA)’s Request for Information regarding the need to update the Control of Hazardous Energy standard, commonly known as Lockout/Tagout. OSHA is looking to modify the language/definitions and actual methods in place for the manufacturing sector. These measures are set in place to protect employees from injuries during the start up or shut down of machinery.
Summary of the Coalition's Comments
The following comments were sent in response to the Request for Information (“RFI”) published by OSHA of the U.S. Dept. of Labor (“DOL”) on May 20, 2019 regarding potential modification of OSHA’s standard governing the Control of Hazardous Energy (“Lockout/Tagout”). (“The Standard”) 84 Fed. Reg. 22756.
- ABA and its members support the comments developed and filed by the Coalition for Workplace Safety (a group of associations and employers who believe in improving workplace safety through cooperation, assistance, transparency, clarity, and accountability). Specifically ABA agrees that….
- The Standard is outdated and needs to be updated with many technological advancements
- OSHA must account for the role that robotics plays in commerce
- OSHA must allow employers flexibility in determining how to protect their employees from hazards
- Certain language and definitions must be updated and re-defined in order to ensure transparency and safety
Summary of ABA's Additional Comments
- ABA’s additional comments regarding this Request for Information (“RFI”)
- Updating specific language regarding “Reliable Control Circuits” and its use versus energy-isolation. The current language is vague and confusing to employers and could in turn lead to inadvertent danger in certain situations.
- There must be full steps to isolate all forms of energy to provide safety for employees
- Interlocks cannot be considered a safe alternative to completely isolating the electrical energy to the equipment.
- If lockout/tagout is not used, than alternative methods should be used only after the hazards have been assessed and risks documented
- Robotics must be addressed in the new Standard – this would be beneficial not only to the baking industry but to all sectors of manufacturing
- Updating specific language regarding “Reliable Control Circuits” and its use versus energy-isolation. The current language is vague and confusing to employers and could in turn lead to inadvertent danger in certain situations.
