Health & Safety Insights

There’s a potential change on the horizon coming to OSHA’s lockout/tagout (LOTO) standard, and employers should pay attention. In an effort to keep up with recent technological advancements that employ computer-based controls of hazardous energy, OSHA issued a Request for Information (RFI) to better understand the strengths and limitations of this new technology, as well as potential hazards to workers.

Request for information

In May 2019, OSHA issued a RFI regarding two areas that look to modernize the LOTO standard at 1910.147 by better promoting worker safety without additional burden to employers, which include:

• Control circuit type devices, and
• Robotics.

Controlling hazardous energy through the use of these computer-based controls has become more prevalent as equipment manufacturers modernize their designs. This approach is more accepted in other nations, which raises the question of whether the U.S. standards should harmonize with those of other countries.

All submissions to the RFI should’ve been submitted on or before August 19, 2019. OSHA will use the information received to determine what action, if any, it may take to reduce regulatory burdens while maintaining worker safety. As of June 2024, a Notice of Proposed Rulemaking based on the information collected, the next step in the regulatory process, has yet to be initiated.

Control circuit type devices

Push buttons, selector switches, and other types of control circuit type devices have been excluded from OSHA’s standard definition of an energy isolating device (EID) due to concerns that the safety functions of these devices could fail as a result of component failure, program errors, magnetic field interference, electrical surges, or improper use or maintenance.

Currently, all hazardous energy from power sources and energy stored in the machine itself is required to be controlled using EIDs when an employee is performing servicing or maintenance of a machine or equipment. This ensures that machines won’t restart while an employee is in a hazardous area.

Over the years, some employers have stated that they believe control circuit type devices that use approved components, redundant systems, and control-reliable circuitry are as safe as EIDs. There have been a number of claimed benefits compared to EIDs, including:

• Workers’ greater willingness to use such devices,
• Better efficiency,
• Less downtime, and
• The lack of a requirement to clear programming on computer-controlled devices.

Robotics

Because robots may contain hazardous energy, OSHA is considering changes to the LOTO standard that would reflect new industry best practices and technological advances for hazardous energy control in the robotics industry.

Traditional robots typically have a fixed base and are kept separate from workers during the operating stage. Newer robots are more mobile and may be allowed to roam freely in a specified area, even if that area is separate from employees. Collaborative robots go a step further by working with human workers. In some cases, such robots are worn directly by the employees themselves (e.g., as exoskeletons).

OSHA is studying the evolution of robotics in the workplace and how this affects employee protections related to the control of hazardous energy.

Some concerns OSHA has with the control of hazardous energy in robots, which use software to operate, include:

• Protection from malware;
• Tampering; and
• Other threats, including signs of robot malfunction.

Key to remember: Proper LOTO practices and procedures safeguard workers from hazardous energy releases. As technology advances and the world adapts, the U.S. is in a position to make changes to the standard that will protect workers from injury or death.