By knowing the history and evolution of OSHA 29 CFR 1910.147 and ANSI Z244.1, OSH professionals can more effectively address current prevention and compliance issues related to the control of hazardous energy.
The original Z244.1-1982 and OSHA's 1989 regulation were based on the technology and knowledge as of 1975.
While Z244.1 has evolved since 1982, OSHA's regulation has remained unchanged for more than 25 years. Relying on requirements that date back to 1989 and before impedes safety progress.
Competing views exist on the requirements for how and when to control potentially hazardous energy. On one hand is OSHA's 29 CFR 1910.147 standard, promulgated in 1989. On the other hand is ANSI/ASSE Z244.1-2016, a voluntary consensus safety standard written by industry stakeholders to address the control of potentially hazardous energy. Although the common goal of both standards is to protect workers from harm, some conflicts arise over how to achieve this goal. Furthermore, significant differences between the requirements in these documents have created confusion as to how to best control hazardous energy to protect employees.
This article, excerpted from The Battle for the Control of Hazardous Energy (Main & Grund, 2016), reviews the history of these standards to help safety professionals understand and appreciate the changes that have occurred over time; explains why the requirements are the way they are; and explores why conflict exists over the interpretation and application of the standards. Understanding the history and developments will help OSH professionals implement effective hazardous energy control solutions.
An employer has a legal right to contest any citation it receives from OSHA if the employer believes it did not violate a standard. In this regard, understanding the history of the standard can help an employer understand why certain solutions are prohibited under OSHA; support its effort to contest and defend against an OSHA citation(s); and, more fundamentally, apply the current standards to prevent harm in the workplace.