WASHINGTON — Updates in hazardous energy regulations must maintain workplace safety, reflect technological advancements and offer employers flexibility, according to the Coalition for Workplace Safety (C.W.S.) and the American Bakers Association, a member of the coalition.
The recommendations were part of a C.W.S. response letter to the Occupational Safety and Health Administration (OSHA) regarding potential modifications of the standard governing the Control of Hazardous Energy. OSHA on May 20 requested comments on the regulation. Published in The Federal Register, the request noted that the current rule has its origins in the early 1980s. The rule was promulgated in September 1989 based on a consensus standard published in 1982 by the American National Standards Institute (ANSI).
The A.B.A. said it concurs with several coalition comments to OSHA:
• The standard is outdated and needs to be updated in a way reflecting many technological advancements;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;
• and certain language and definitions must be updated and redefined in order to ensure transparency and safety.
According to OSHA, hazardous energy refers to danger from a variety of energy sources, including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources in machines and equipment that can be hazardous to workers.
“During the servicing and maintenance of machines and equipment, the unexpected start-up or release of stored energy can result in serious injury or death to workers,” according to OSHA.
Traditional methods of protecting workers from this risk include lockout devices that keep an energy-isolating device (such as a manually operated circuit breaker or a disconnect switch) in a safe position, keeping machinery from starting up. An alternative to a lockout device is tagout, which essentially is a warning tag stating that the machinery tagged must not be operated until the tag is removed consistent with established and appropriate procedures.
In recent years, ANSI has recognized that the standards may be dated since advancing technology has opened the possibility of advanced control systems that “provide new opportunities for addressing energy control where conventional lockout is not feasible, where energy is required to perform a task, where repetitive cycling of an energy-isolating device increases risk, and where energy is required to maintain equipment in a safe state.” A new ANSI consensus standard was published in 2016, providing for “decision-making flexibility regarding hazardous energy control.”
The A.B.A. also is advocating the update of specific language in the regulation regarding “Reliable Control Circuits” and their use versus energy-isolation.
“The current language is vague and confusing to employers and could in turn lead to inadvertent danger in certain situations,” the A.B.A. said. “There must be full steps to isolate all forms of energy to provide safety for employees.”
The bakers also said interlocks should not be considered a safe alternative to complete isolate of electrical energy to equipment. When lockout/tagout is not used, alternative methods should be pursued only when hazards have been assessed and risks documented.
Amplifying the C.W.S. point on the importance of addressing robotics in the new standard, the A.B.A. said such a modification “would be beneficial not only to the baking industry but to all sectors of manufacturing.”