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Minor Servicing Exception

Per OSHA, some Servicing tasks performed during normal production operations are not covered under the Lockout/Tagout standard. This exception is commonly known as the Minor Servicing Exception.

The minor Servicing exception is contained in a note to 1910.147, Paragraph (a)(2)(ii), that states the following:

Note: Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).

With that in mind, it is the general consensus that the Lockout/Tagout standard is not intended to cover minor Servicing activities that are necessary to carry out the production process provided that associated danger zones are properly guarded.

There are three specific criteria that can be used to determine if the minor Servicing exception would apply to a particular task or activity as follows:

  1. The activity must be conducted during normal production operations, i.e., while the machine or equipment is actually performing its intended production function.
  2. The activity must be:
    • Routine: The activity must be a regular course of procedure and be in accordance with established practices.
    • Repetitive: The activity must be regularly repeated as part of the production process.
    • Integral: The activity must be essential to the production process.
  3. If all of these apply, the employer must use alternative measures to provide effective protection from the hazardous energy. Some acceptable alternative measures include specially designed tools, remote devices, interlocked barrier guards, local disconnects, or control switches which are under the exclusive control of the employee performing the minor servicing. These alternative measures must enable the employee to safely perform the servicing task without being exposed to the unexpected energization or activation of the equipment, or the release of stored energy.

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last modified: May 07, 2019   Printer Friendly   Top