Lock-Out/Tag-Out ANPRM to OMB

Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had received an advanced notice of proposed rulemaking (ANPRM) from DOL’s Occupational Health and Safety Administration (OSHA) for changes to their Lock-Out/Tag-Out regulations.

The abstract for this rulemaking in the Fall 2018 Unified Agenda notes:

“Recent technological advancements that employ computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with OSHA's existing lock-out/tag-out standard. The use of these computer-based controls has become more prevalent as equipment manufactures modernize their designs. Additionally, there are national consensus standards and international standards harmonization that govern the design and use of computer-based controls: this approach of controlling hazardous energy is more accepted in other nations, which raises issues of needing to harmonize U.S. standards with those of other countries. The Agency has recently seen an increase in requests for variances for these devices. This RFI will be useful in understanding the strengths and limitations of this new technology, as well as potential hazards to workers.”

One of the contract jobs I did during my first break from the chemical industry was as an industrial safety instructor for a major greenfield manufacturing facility. One of the classes that I spent a great deal of time developing and then presenting to new employees was the mandatory LOTO training, both for affected and authorized employees. I have a special place in my heart for this safety program. But the reason that I am including this rulemaking notice in my blog has more to do with the cybersecurity implications of the possible rulemaking.

Anytime that we start to consider adding “computer-based controls of hazardous energy” to a safety program we need to ensure that the security of those controls are very carefully taken into account. Failure to do so will place workers in needless danger.