OSHRC rules on “unexpected energization” in LOTO standard

By Mike Taubitz

In a significant decision, the Occupational Safety and Health Review Commission has ruled that OSHA’s lockout/tagout standard cannot be applied where unexpected energization cannot occur.

The decision stemmed from a case in which Alro Steel Corp. was cited for a serious violation regarding the company’s practices for changing band saw blades. OSHA contended that the company’s use of a push button as an “energy isolating device” did not conform to the LOTO standard, which governs unexpected energization.

But Alro said that the standard could not be applied because there was no possibility of unexpected energization during the blade change.

One of Alro’s experts testified that, in fact, there were six elements on the one of the saws to keep the blade from moving; the blade power-on switch, the emergency e-stop switch, the spring loaded start switch, the PLC (program logic controller) switch, and two interlocks. He stated “to me it’s a wild exaggeration to think that all six could fail.”

A second expert, a professional engineer with an electrical engineering background said that, based on the electrical design of each machine, they would not energize unexpectedly during a blade change when the motors are de-energized and locked out at the control panel. He also commented that, based on the electrical design of the machines, unexpected energization would not occur, even if the control circuit components failed.

The Commission found that the preponderance of the evidence demonstrated that neither of Alro’s saws was subject to inadvertent startup and unexpected energization. Moreover, the evidence established that for the saws to start, the operator was required to engage in a multi-step process, including reaching into his pocket for a key and unlocking the start button.

The Commission found that OSHA failed to establish that the saws were subject to unexpected energization when changing blades, and overturned the citation.