As a follow up to the comments submitted in August of this year, SGIA Government Affairs staff met with key OSHA representatives regarding the information provided to OSHA in response to their request for feedback on revising the Lockout/Tagout Standard. Overall, the meeting went very well and the response from OSHA was positive on several key issues.
The meeting opened with SGIA staff providing a summary of the key components contained in the comments. One of the main points was that OSHA needs to maintain the word “unexpected” as in “protection from unexpected energization” in the standard. It was explained that the “inch-safe-service method” that is acknowledged by OSHA is premised on the fact that it protects equipment operators from unexpected energization during minor servicing and maintenance. OSHA indicated unexpected will remain unchanged in the standard.
Regarding legacy equipment, OSHA indicated that existing equipment needs to be addressed in a different manner than new equipment that is incorporating the newer reliable control technology for safety systems. It was explained that the costs associated with performing a risk assessment and identifying and installing the designated reliable control technology is not technically or economically feasible. It was reiterated that the “inch-safe-service-method” is safe when followed. It was also stated that the type of activities using this method should be expanded to include more make-ready and set up activities. OSHA did not commit as to how legacy equipment will be addressed in the revised standard.
It was stressed that changes in the standard that would recognize the newer reliable control technology for safety contained in several consensus standards (e.g., ISO, ANSI, IEC, etc.) should be mandated for new equipment manufactured at some point in the future after the standard is revised, if OSHA were going to mandate conformance with those standards. While some equipment currently being manufactured does meet the requirements now, not all meet it and time would be required for some manufacturers to conduct the risk assessment and incorporate the technology.
OSHA was very appreciative of the comments and the conversations held during the meeting. OSHA expressed a desire to have an ongoing dialog about the potential revisions to the standard and may want to visit some printing operations to gain a better understanding of how operators use the equipment and interact with it during its operation.
The meeting opened with SGIA staff providing a summary of the key components contained in the comments. One of the main points was that OSHA needs to maintain the word “unexpected” as in “protection from unexpected energization” in the standard. It was explained that the “inch-safe-service method” that is acknowledged by OSHA is premised on the fact that it protects equipment operators from unexpected energization during minor servicing and maintenance. OSHA indicated unexpected will remain unchanged in the standard.
Regarding legacy equipment, OSHA indicated that existing equipment needs to be addressed in a different manner than new equipment that is incorporating the newer reliable control technology for safety systems. It was explained that the costs associated with performing a risk assessment and identifying and installing the designated reliable control technology is not technically or economically feasible. It was reiterated that the “inch-safe-service-method” is safe when followed. It was also stated that the type of activities using this method should be expanded to include more make-ready and set up activities. OSHA did not commit as to how legacy equipment will be addressed in the revised standard.
It was stressed that changes in the standard that would recognize the newer reliable control technology for safety contained in several consensus standards (e.g., ISO, ANSI, IEC, etc.) should be mandated for new equipment manufactured at some point in the future after the standard is revised, if OSHA were going to mandate conformance with those standards. While some equipment currently being manufactured does meet the requirements now, not all meet it and time would be required for some manufacturers to conduct the risk assessment and incorporate the technology.
OSHA was very appreciative of the comments and the conversations held during the meeting. OSHA expressed a desire to have an ongoing dialog about the potential revisions to the standard and may want to visit some printing operations to gain a better understanding of how operators use the equipment and interact with it during its operation.