2 You indicated that these machines are seldom equipped with light curtains or other protective devices for the point-of-operation. Parts are secured by clamps, oiling is accomplished continuously with coolant pumps, and the machine's controls are located well away from the points of operation. You have noted that the training requirements for, and skill levels of, milling machine operators are necessarily high in order to achieve the required milling precision and that there is no need for the operators to place their hands near the point of operation on milling machines during normal production operations. You further stated that these activities are not covered by the LOTO standard if the work is performed using alternative protective measures that ensure employee safety, such as those required by, Subpart O.
Your Subject Background: You stated that OSHA has issued interpretation letters addressing the lockout/tagout (LOTO) "minor servicing" exception for certain tool changes, cleaning, un-jamming, and other minor servicing activities that are routine, repetitive, and integral to the use of machines for production purposes.
Your paraphrased subject background (with comments), questions, and our replies follow: 147, requirements for vertical/horizontal milling machine and drill press tool changes. You had specific questions regarding The control of hazardous energy (lockout/tagout) standard's. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Thank you for your Decemletter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs.
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