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.
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