July 1, 2015

Mr. Jeff Wilke, Safety Director
Alter
700 Office Parkway
St. Louis, MO 63141

Dear Mr. Wilke:

Thank you for your February 12, 2015 correspondence to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs. You requested that OSHA provide an interpretation of how the lockout/tagout requirements in 29 CFR 1910.147, apply to lockout and tagout of vehicle-type mobile construction equipment, such as front end loaders, during maintenance.

Question 1: Does servicing mobile equipment, such as front end loaders, with the electrical circuit locked and tagged out, tires blocked, and the lifting arms set on the ground to eliminate gravitational hazards meet the requirements of 29 CFR 1910.147?

Response: Servicing mobile equipment in the manner described above would likely meet the requirements for control of any hazardous energy (including the hazards of servicing split-rim wheels). It would also be prudent to follow the pertinent sections of the manufacturer’s service manual when servicing the equipment.

Question 2: Using the scenario in question 1, does changing out loader attachments, where the hazard potential is attachments falling once hydraulic parts are operated, require a lockout procedure?

Response: The employer shall consider all potential hazards from unexpected startup or release of stored energy, including the gravitational effects on loose equipment parts; and take action necessary to eliminate or minimize such hazards.

Question 3: If the answer is that we must implement a way to effectively lockout for gravity in situations described in question 2, how would you go about accounting for, developing, and training mechanics on such situations that are not routine and sometimes are created during a one-time servicing situation or during assembly or disassembly?

Response: 29 CFR 1910.147(c)(7), Training and communication, explains how to comply with training requirements for the control of hazardous energy. Appendix A, of 29 CFR 1910.147, is an example lockout procedure. These items will assist in your development of training.

Question 4: Is it acceptable, as a replacement for writing our own procedures, to reference (in our written lockout program) that specific service and safety procedures for this equipment can be found in the manufacturers operations manual for mobile equipment that you can reference for conducting service on equipment?

Response: The equipment manufacturer’s manual is a good initial source of information the employer can use to ensure their employees are not exposed to any hazards, or are protected from such hazards. 29 CFR 1910.147 requires employers to establish an energy control program consisting of energy control procedures, employee training and periodic inspections. If the employer elects to follow the equipment manufacturer’s guidance, such guidance must contain all of the elements of a LOTO program pursuant to the requirements of 29 CFR 1910.147; thereby ensuring employees are not exposed to any other hazardous energy.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA’s interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA’s website at https://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs