Jam Clearing, a Foot Switch, and a Contractor's Tag
At a carton plant, the case packer jams six to eight times per shift. Operators clear jams by reaching through an 8-inch by 10-inch opening in the machine's side panel - there is no interlock - to pull out crushed cartons while the machine is energized. The machine can be restarted from a foot switch that a co-worker at the infeed operates. The company's lockout program requires locks only at the main disconnect at the end of the shift, and the plant manager calls jam clearing "minor servicing, so we don't lock out." Last month a contractor replacing the glue unit applied a tag only, because the contractor's locks were tied up on another job; the host's lockout procedure says nothing about contractors.
1. Does the minor servicing exception apply to the jam clearing? State the test and apply it.
Read the worked answer
The exception does not apply as practiced.
The test (1910.147(a)(2)(ii)): servicing or maintenance is exempt from lockout/tagout only when it is minor - that is, routine, repetitive, and integral to the use of the equipment for production - and the work is performed using alternative measures that provide effective protection. All parts of the test must be met.
Applying it:
- Routine, repetitive, integral? Yes - six to eight times a shift, tied directly to production.
- Effective alternative protection? No. Reaching through an unguarded, non-interlocked opening puts the operator's hand in a hazardous area where the machine can cycle, and a co-worker at the foot switch can restart it without warning. The recognized alternative protection for this kind of task is an interlocked guard that prevents the machine from operating (or from being started, including from the foot switch) while the opening is open.
- Where the line is: if clearing the jam requires any part of the body to be placed where the machine could injure it, and there is no interlock or equivalent safeguard, the task is not minor servicing and full lockout/tagout is required before the panel is opened.
Related violation: the unguarded 8 x 10-inch opening is also a machine-guarding failure under 1910.212(a)(1) - openings in guards and at the point of operation must be constructed so hands cannot reach the danger zone. The correct fix is engineering: interlocked guards plus a jam-clearing procedure, not a lecture to operators.
Lockout mechanics for this machine (1910.147(c)(4), (d)): machine-specific written procedure, notify affected employees, shut down normally, isolate the main disconnect and the control-circuit/foot-switch energy, apply a personal lock and tag per authorized employee, release stored energy (pneumatics), and verify isolation by attempting startup after lockout. The foot switch must not be able to start the machine during servicing.
2. The contractor used a tag only. What does 1910.147(f)(2) require of the host and the contractor, and is tag-only acceptable here?
Read the worked answer
Tag-only is not acceptable, and the host has unmet coordination duties.
Coordination (1910.147(f)(2)):
- The host must inform the contractor of the plant's lockout/tagout procedures, the hazardous energy present, and the rules the contractor must follow.
- The contractor must inform the host of the lockout/tagout procedures it will use.
- The host must ensure the contractor complies with the plant's procedures and the standard - not simply hand over the area.
- Where both host and contractor employees work on the same equipment, the two programs must be coordinated, typically through a group lockout with a lockbox and each worker applying a personal lock or a documented equivalent (1910.147(f)(3)).
Why tag-only fails:
- Tagout may be used in lieu of lockout only when the employer can demonstrate that lockout is infeasible or that the tagout provides full employee protection (1910.147(c)(5)). Here the disconnect has a hasp and the host already owns locks - lockout is plainly feasible.
- Tags are warning devices only; they do not prevent operation and can be removed. That is why a tag-only system requires additional means (removal of a control component, blocking a switch, etc.) to achieve the same protection, plus documented justification.
- "Our locks are on another job" is a resourcing failure, not an infeasibility finding. The fix is a contractor lock supply requirement in the contract and a site-specific lockout orientation before the contractor starts.
Program fixes: add a contractor section to the written procedure, require contractor sign-off on the host's energy control rules, and audit contractor lockouts during the job.
3. An OSHA compliance officer is likely to ask about the program itself. Identify the biggest program gaps and what an effective annual review would have caught.
Read the worked answer
Gaps the program almost certainly has:
- No machine-specific written procedures (1910.147(c)(4)(i)–(ii)): the program stops at the disconnect and ignores the control circuit, the foot switch, and stored pneumatic energy. Written procedures must identify the energy sources, isolation points, and verification method for each machine.
- No periodic inspection (1910.147(c)(6)): required at least annually for each procedure, performed by an authorized employee other than the one who uses the procedure - often the single most missed element - and certified in writing with the machine, date, employees included, and the inspector's name.
- Training (1910.147(c)(7)): authorized, affected, and "other" employees need distinct training, with certification of names and dates. A co-worker who restarts the packer from the foot switch without knowing a lockout is in progress is an affected employee who was never trained or notified.
- Devices (1910.147(c)(5)): locks and tags must be standardized, durable, and identifiable to the individual authorized employee, with documented procedures for removal when the employee is unavailable.
- Energy control verification (1910.147(d)(6)): the program must require attempting startup or measuring to prove isolation before work begins.
- Machine guarding interface (1910.212(a)(1)): the unguarded opening and the foot-switch restart are guarding problems that no amount of lockout training will fix.
What an annual inspection would have caught: an authorized employee other than an operator walking the packer procedure would have seen that the procedure does not cover the control circuit, that operators clear jams live, and that the documented "minor servicing" rationale has no interlock behind it - the exact chain of findings the compliance officer will document.