Scenario: You are the Risk Manager for a large auto dealership and service/repair garage group. Over the past few months, you have heard about a couple serious injuries that have occurred in auto service garages involving vehicle maintenance and you decide you want to increase your focus on safety and begin developing Job Hazard Analyses for the routine vehicle maintenance activities. As these are developed, you realize the employees are being exposed to various forms of hazardous energy and you begin to believe that the implementation of the OSHA Control of Hazard Energy (Lockout/Tagout) standard may help eliminate, or at least mitigate, the hazards to which they are being exposed when performing vehicle maintenance. When you present this plan to the owner of the dealership group, you are told that this has not been industry practice in the past and he doesn’t believe the OSHA standard includes this industry group. He is not going to commit to the implementation of such a program unless you can show him that this standard does apply to servicing and maintaining automobiles.
Question: Does the OSHA standard 29cfr1910.147 “Control of Hazardous Energy (Lockout/Tagout)” apply to the service and maintenance of automobiles?
Answer: OSHA Directive CPL 02-00-147 “The Control of Hazardous Energy – Enforcement Policy and Inspection Procedure” states some machines and equipment covered by the control of hazardous energy standard include automotive repair, service, and garage machinery and equipment, including automobiles, trucks, material handling equipment, tire repair machines, hoisting equipment, automotive lifts.
The Directive Chapter 3 Section III titled Vehicle Hazardous Energy Control states “Serious injuries and death have occurred and continue to occur from inadequate hazardous energy control during vehicle servicing and maintenance activities. In 1991, the U.S. Court of Appeals for the District of Columbia remanded the LOTO standard to OSHA for further consideration of the ways in which the final rule applies to all general industry workplaces. OSHA, in the March 30, 1993 Federal Register (Vol. 58, No. 59), reaffirmed and further explained the reasons for applying the standard to vehicle servicing and maintenance. The scope and application sections of the preamble to the hazardous energy control standard provide that the LOTO standard applies to all “general industry workplaces.” The standard’s coverage includes vehicles, such as, but not limited to, automobiles, trucks, tractors, refrigeration transport vehicles, and material handling equipment.
This section clearly defines what OSHA believes could be hazardous energy for purposes of vehicle servicing and maintenance. It requires employers to develop an energy control program that is tailored to the workplace and will protect employees performing servicing and maintenance tasks from the release of hazardous energy.
One comment in the directive states that it should be noted that turning off the engine and removing the car key is not, strictly speaking, the same as applying a lockout or tagout device to an energy isolating device because neither the ignition switch, nor the key, are energy-isolating devices. OSHA allows the key removal practice only when the key removal fully ensures employee protection.
Can you use a combination lock when performing Lockout/Tag Out? Click here for the answer.