OSHA periodically updates its regulations by making technical corrections under its “Standards Improvement Project” process. Usually, these revisions are not controversial and are considered minor. However, OSHA included the change in the Lockout/Tagout Standard in direct response to loosing a court case. The case involved GM-Delco’s successful defense showing that employees were not exposed to “unexpected” energization during servicing and maintenance of equipment. OSHA’s position is that all equipment must be completely deenergized during servicing and maintenance activities. GM was able to show employees were protected from injury due to a series of safety systems that allowed the equipment to remain powered or energized, but unable to run, while they serviced the equipment.
The significance for the printing industry is that there are several letters of interpretation issued by OSHA that allow employees to conduct many activities under the minor servicing and maintenance provision in the Lockout/Tagout Standard while the equipment is energized, but unable to run. The letters of interpretation require that some form of alternative equivalent protection be provided to protect employees from injury due to machine motion such as conformance with ANSI standards that address drive controls and warning systems, machine guards, or special techniques or tools. Removing the word “unexpected” from the standard would have made the letters of interpretation null and void thus requiring printers to completely deenergize and lockout equipment for any servicing and maintenance activity.