by Jonathan Poole
Senior EHS Consultant

No matter how frequently the control of hazardous energy is featured on OSHA’s annual list of the Top 10 Most Cited Violations (#6 for 2022), lockout/tagout (LOTO) fails to receive the attention it deserves at many manufacturing facilities and remains a black eye for safety programs across the nation.  Because LOTO procedures take time, the process impacts production and ultimately undermines the bottom line.  For this reason, managers often embrace exceptions to the 29CFR 1910.147 requirements and encourage workers to avoid locking/tagging out machines whenever possible.  Unfortunately, this strategy results in senseless tragedies and/or needless OSHA citations when mistakes are made, and hazardous energy controls are omitted by mistake.  

Perhaps no exception to LOTO appears more tempting to apply than the cord and plug exception, 1910.147 (a)(2)(iii)(A), which bluntly states that lockout/tagout does not apply to:

Work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.

In essence, this exception appears to set aside the use of lockout/tagout in situations where unplugging a machine eliminates all sources of hazardous energy, including the potential for stored energy and the possibility of re-energization of the machine.  Since countless machines and power tools in American facilities appear to fit these simple criteria, LOTO of corded equipment is regularly excluded from safety routines.  All things considered, is this a good idea?

Before we dismiss the general use of lockout/tagout with electrical cords, let us consider OSHA’s interpretation of the exception.  First, as stated in the standard, unplugging the machine must address ALL potential sources of hazardous energy.  That includes all forms of hazardous energy (potential, kinetic, pneumatic, thermal, etc.) as well as residual or stored energy within the corded machine.  Consider a machine with electrical energy that can be isolated by unplugging that also includes pneumatic or hydraulic energy that must be addressed by isolating a separate source.  Will your employees identify the separate valve(s) or follow the required Energy Control Procedure (ECP) that details all sources of energy and isolation points?  Might they dismiss LOTO the moment they see the electrical cord and forget the other sources of hazardous energy?

Or what if a machine can be unplugged but has a separate battery backup in case of loss of electrical power?  Consider the consequences of assuming that corded machines cannot store electricity then initiating repairs after unplugging them.  Obviously, some faith must be placed with personnel when allowing them LOTO discretion, but are all your authorized users familiar with the nuances of every machine you have onsite?

Still, my personal apprehension with avoiding LOTO and corded machines centers around the concept of “exclusive” control.  How might an individual focused on servicing a machine in some way maintain exclusive control over a cord?  Might the employee keep it in his/her line of sight or in his/her lap while working on the machine?  How long can the cord be before it is out of an individual’s exclusive control?  What if an extension cord or other outlet device is involved?  What if multiple individuals are servicing a machine simultaneously?  Does the number of employees involved impact the risk associated with an unplugged machine?

Exclusive control over an electrical cord translates into awareness and management of the cord during work activities.  The temptation to plug in an electrical cord is so inviting that I do not consider omitting lockout/tagout whenever the cord is longer than five feet or positioned in such a way that the individual performing servicing cannot keep his/her eyes on it.  Regardless of the cord length or position, I believe locking/tagging out the cord efficiently eliminates a distraction that most employees do not need to worry about while completing a repair.

In my experience, the decision to not lockout/tagout electrical cords is trickier than one might expect.  If you have ever used a cord isolation device with a lock, you probably realize that we are debating a few seconds of effort for unlimited protection.  As with all scenarios involving hazardous energy, lockout/tagout addresses every potentially dangerous outcome, including unanticipated events.  Why take the chance with electrical cords when the investment into time and equipment is relatively minimal?    

Many EHS Managers continue to believe that the LOTO standard, 29CFR 1910.147, can be summarized with a handful of absolute statements, including exceptions to the rule.  Decisions regarding electrical cords once again demonstrate that the variables involved with controlling hazardous energy are too many to consider; thus, LOTO remains the best, comprehensive solution in almost all scenarios.  Remember, the exceptions to LOTO standards do not include convenience as a worthwhile reason for omitting energy isolation protection.  Employers remain responsible for worker safety, so make sure your facility’s lockout/tagout policy addresses all of the risks that are involved with hazardous energy, including the use of something as simple as electrical cords.   

How We Can Help
Hazardous Energy Programs present challenges to all facilities, including those that strive for the safest work environment possible.  The EI Group’s safety experts provide LOTO training, procedure development and EHS consulting services that can help you update your Hazardous Energy Program and make it an asset instead of a liability.  If you have any questions regarding lockout/tagout, contact Jonathan Poole, Senior EHS Consultant with EI, at (919) 459-5252 or [email protected].