The standard requires energy control procedures specific to each machine. Most companies have a general program and nothing behind it — which is exactly what gets cited after someone is caught in a machine.
A general program describes the policy. The standard requires documented procedures identifying the energy sources, isolation points and verification steps for each machine. This is the most common citation in the standard.
Pneumatic pressure, hydraulic accumulators, gravity, springs and capacitors kill people after the electrical disconnect is locked. Procedures that stop at the breaker are incomplete.
The standard requires a periodic inspection of each energy control procedure by an authorized employee other than the one using it, documented. Almost nobody does this, and it is easy for an inspector to request.
Training requirements differ between authorized, affected and other employees, and records need to show who received which. Blanket annual training for everyone does not satisfy it.
When outside servicing personnel work on your equipment, both sides must inform each other of their respective procedures. This is routinely undocumented.
Multi-person servicing and shift handover require specific provisions. Companies that do single-person lockout well often have nothing written for the group case.
We survey each machine, identify every energy source including stored energy, document the isolation points and verification steps, and produce a procedure that an authorized employee can actually follow at the machine — usually with photographs of the isolation points.
Then we build the parts that make it hold: the authorized employee training and records, the annual inspection process and documentation, the group lockout and shift-change provisions, and the contractor coordination language.
Nearly. There is a narrow exception for equipment with a single energy source that is readily identified and isolated, with no stored energy and no potential for reaccumulation, among other conditions. Most production equipment does not qualify, and assuming it does is a common error.
Yes, if they are truly identical in energy sources and isolation points. Differences in installed utilities or retrofits break that, so identical model numbers are not sufficient on their own.
When the procedure, machine or job changes, and whenever a periodic inspection reveals a deviation. There is no automatic annual requirement for retraining, though the annual procedure inspection is required.
Equipment under exclusive control of the person servicing it via unplugging is treated differently, but exclusive control is the operative condition and it is often assumed rather than achieved.
Depends on machine count. Roughly fifteen to thirty procedures per week of survey work, plus review and training rollout.
If those two numbers do not match, that gap is your exposure. Twenty minutes to scope closing it.
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