OSHA: Response to Query Regarding LOTO and the Inch-Safe-Service Technique

Date First Published on SafetySmart Compliance: September 9th, 2011
Topics: Lockout Tagout | Machine Guarding |

Retrieved from: Occupational Safety & Health Administration


Your letter raises specific questions regarding the application of the Control of hazardous energy (lockout/tagout) standard, 29 CFR 1910.147, in the printing industry. This response will comment on OSHA’s September 16, 1992 letter to John Runyan and the June 14, 1993 follow-up memorandum to OSHA Regional Administrators. This background, your questions, and our replies follow. 

Application of the Lockout/Tagout Standard. The lockout/tagout standard applies to servicing and maintenance performed on numerous machines and pieces of equipment in an array of industries, including the printing industry. Servicing and maintenance activities are necessary adjuncts to the industrial process, enabling machines or equipment to perform their intended functions. The core of the lockout/tagout standard, which permits employees to work on machines or equipment safely, is the shutdown and de-energization of machinery and the isolation of energy source(s), which is accomplished through the application of hazardous energy control measures. This normally consists of stopping the machine or equipment, isolating it from its energy source(s), locking or tagging out the energy isolating devices, releasing or relieving stored or residual energy, and verifying that the machine or equipment is safe to work on. All energy control activities must be conducted in accordance with procedures developed, and in most cases documented, by the employer for the purpose of controlling hazardous energy. 

In promulgating the standard, OSHA recognized circumstances in which servicing and maintenance activities would be performed (in full or in part) without locking or tagging out the machinery or equipment. One such circumstance is detailed in §1910.147(f)(1), which recognizes that lockout/tagout devices must be temporarily removed in limited situations to permit testing or repositioning and establishes procedural steps to maintain the integrity of any lockout/tagout program. 

Another such circumstance is detailed in the exception to 1910.147(a)(2)(ii) and is referred to as the minor servicing exception. OSHA recognized that, “if the servicing operation is routine, repetitive, and must be performed as an integral part of the production process, lockout or tagout may not be necessary because these procedures would prevent the machine from economically being used in production.” 54 FR 36644, 36662 (September 1, 1989), as amended at, 55 FR 38677, 38679 (September 20, 1990). Thus, the Agency adopted the minor servicing exception. The exception provides that:

Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).

It is important to note that the lockout/tagout standard applies only if workers are exposed to hazardous energy during servicing and maintenance activities. The lockout/tagout standard complements the requirements for machine safety prescribed by various general industry standards in 29 CFR Part 1910, and an employer may avoid the requirements of the lockout/tagout standard, if the employer protects employees from exposure to hazards throughout the servicing and maintenance process by using machine guarding in accordance with the Machine Guarding requirements of 29 CFR Part 1910, Subpart O. In other circumstances, such as during some machine set-up operations, it is necessary to supplement lockout/tagout procedures with machine guarding (a.k.a. safeguarding [barrier guards, safeguarding devices]) methods to adequately protect employees from the hazardous energy.

OSHA’s September 16, 1992 letter. The printing industry has posed questions over time regarding the application of the lockout/tagout standard, particularly the application of the minor servicing exception. OSHA explained in a September 16, 1992 letter to John Runyan that the machine guarding standards apply to normal production operations, while the lockout/tagout standard applies during servicing or maintenance activities. The lockout/tagout standard applies whenever employees engaged in servicing or maintenance bypass guards or otherwise become exposed to hazardous energy; if employees performing servicing or maintenance are not exposed to hazardous energy, the standard does not apply. 

The following tasks were identified in the September 16 letter as examples of minor servicing activities commonly performed (during normal production operations) in the printing industry: a) clearing certain types of paper jams; b) minor cleaning, lubricating, and adjusting operations; c) certain plate and blanket changing tasks; and, d) in some cases, paper webbing and paper roll changing. The letter also provided that the inch-safe-service technique used in conjunction with the main drive control appeared to provide effective alternative protection for these minor servicing activities. The letter further recognized that this technique was consistent with the use of controls specified in the American National Standard Institute (ANSI) standards B65.1 (1985) and B65.2 (1988) for web- and sheet-fed printing presses for which, as a minimum, a stop/safe/ready function must be available at the designated control stations.

As emphasized above, the September 16 letter did not state that all un-jammingcleaning lubricating, adjusting, plate/blanket changing,and paper webbing/paper roll changing operations in the printing industry were subject to the minor servicing exception. As previously described, employers can use effective alternatives to lockout/tagout only in the limited circumstances outlined in the 1910.147(a)(2)(ii) exception. Thus, for example, a normal blade changing operation on a guillotine paper cutter would not qualify for the minor servicing exception because, among other things, the activity is performed infrequently and cannot be done while the machine is operating in a production mode. This task would need to be performed pursuant to an energy control procedure that specified the lockout/tagout steps and any machine guarding methods necessary to control employee exposure to hazardous energy associated with the cutter.

Response to your letter. Your letter poses three questions; our replies follow: 

Question #1: The June 14, 1993 memo to OSHA Regional Administrators, regarding the Applicability of the machine guarding and lockout/tagout standards to printing presses, has been interpreted as not recognizing the inch-safe-service technique as alternative, equivalent protection for some pieces of equipment. The existing clarification does not define a “printing press,” and therefore, some have concluded that the inch-safe-service technique could not be used for minor servicing activities on binding and finishing systems. However, some printing presses have integrated cutting, folding, and delivery devices. For purposes of the OSHA lockout/tagout standard, what is the definition of a “printing press”? 

Reply: The lockout/tagout standard does not define a “printing press,” as the standard addresses generally the servicing and maintenance of equipment and machinery. However, the interpretive guidance and policy contained in OSHA letters, compliance directives, and relevantFederal Registers may address specific machines or pieces of equipment. Ultimately, in every case, employers must analyze alternative methods in light of the functions and operations of the specific machinery, and employers can use an alternative method only if it effectively protects employees from exposure to hazards otherwise incumbent with the servicing and maintenance activities. 

In response to input received after issuing the September 16 letter, OSHA issued a memorandum on June 14, 1993. The memorandum explained that the September 16 letter provided guidance only with respect to effective alternative protection for minor servicing activities in conjunction with printing processes. From your letter, it appears that the June 14 memorandum has been interpreted to state that the inch-safe-service technique does not constitute effective alternative protection for minor servicing activities performed on binding and finishing systems — such an interpretation is incorrect. Rather, the memorandum merely reserved the question of whether the inch-safe-service technique could provide effective alternative protection during minor servicing performed on binding and finishing systems. As detailed in our reply to your next question, OSHA has considered minor servicing performed on binding and finishing systems and concluded that theinch-safe-service technique may be used to provide effective alternative protection. 

Question #2: Is the inch-safe-service technique, which is used in conjunction with equipment meeting the appropriate ANSI standard for binding and finishing equipment, an acceptable form of alternative equivalent protection for minor servicing activities? 

Reply: The inch-safe-service technique described in this letter and detailed further in the September 16 letter to John Runyan, may be used as alternative effective protection for minor servicing activities associated with binding and finishing equipment with appropriate control systems described in ANSI B65.2. The following summarizes the essential elements of the inch-safe-service technique, including the safeguarding practices: 

  1. Servicing or maintenance must not be conducted when machine components are moving. Before performing any minor servicing, the machine must be STOPPED, and its drive control must be in STOP/SAFE position.
  2. Consistent with the provisions contained in 1910.147(f)(1), procedures to INCH a machine must include a pre-startup check to assure the safe positioning of employees and to assure that all tools, etc. are positioned so that they do not create a hazard for employees.
  3. DEACTIVATE the SAFE function immediately before safely inching the machine component for positioning purposes — a procedural element implicit in the September 16 letter.
  4. By use of the INCH control, the components of the machine are moved to their desired position. Immediately thereafter, the drive control is placed on STOP/SAFE by each employee working in a hazardous area before beginning or resuming the minor servicing work activity.
  5. Steps (2) through (4) are repeated as necessary until the minor servicing is completed.

Question #3: May employers utilize a combination of appropriate machine guarding techniques as specified by ANSI B65.1 and safe work practices as an alternative form of equivalent protection during the performance of a minor cleaning operation called “blanket washing” while the press is energized? This approach would be in addition to the inch-safe-service method with presses meeting the ANSI B65.1 provisions. 

Reply: OSHA permits the use of ANSI standards to abate a hazard, as long as the ANSI standard provides a level of protection that is equal to, or greater than, relevant OSHA standards. With regard to blanket washing, and as described above, compliance with the Machine Guarding, 29 CFR Subpart O, standards can provide an acceptable alternative to lockout/tagout by preventing exposure to hazardous energy. 

It is OSHA’s understanding that, in some instances, employees in the printing industry perform blanket-cleaning operations on the out-running side of an offset printing press while the machine is operated in a “slow run” mode. The press operators use folded towels (containing solvent), which are held in the palm of a hand (so that no loose ends are available), to clean the moving cylinders. These slow moving cylinders have smooth surfaces (e.g., without projection, gaps, notches or other surface features that may grab a towel or otherwise cause injury to workers) that pose no additional hazards during the hand cleaning task. Additionally, if employees are exposed to nip points on the in-running side of the press, barrier guards that fully extend across the entire smooth surface of the rolls are used to provide employee protection from all ingoing nip hazards. The barrier guards must meet the requirements of Subpart O and be adjusted to have no more than a one-quarter- (0.25) inch opening at any point between the guard and the printer rolls.

These described machine-guarding and cleaning techniques prevent employee exposure to hazardous energy while employees perform the roll cleaning; thus, lockout/tagout procedures are not required. However, practices such as reaching around guards, removing guards, and reaching into unguarded danger areas (e.g., to remove a “hickey”) defeat the protective value of machine guards, eliminate effective protection during servicing and maintenance activities, and preclude the application of the minor servicing exception. See §1910.147(a)(2)(ii)(A) and (B). Likewise, the lockout/tagout standard applies if employees are exposed to other hazards created by rollers or blankets, such as uneven revolving surfaces or roller/blanket openings or projections. Under no circumstances is an employee ever permitted to place any part of his or her body within a hazardous area, such as a point-of-operation, ingoing nip points, or around power transmission apparatus, while the equipment or machine is running or energized.