Does Exclusive Control Apply When Locking out Ceiling Disconnects?
Ceiling units are remotely located, and although they are often only accessed by one individual at a time, this does not mean the units fall under the domain of “exclusive control.” Since ceiling units are typically heating, ventilation, and air conditioning (HVAC) units, any individual performing maintenance must be locking out ceiling disconnects in order to comply with the Occupational Safety & Health Administration (OSHA) 1910.147 standard.
In the OSHA 1910.147 lockout/tagout standard, section 1910.147(a)(2)(iii)(A) states an exception to the standard. If a piece of electric equipment has a cord and plug, unplugging the piece of equipment removes all energy, and the employee performing maintenance on the electric equipment has exclusive control of the plug, that the lockout/tagout standard does not apply to this piece of equipment.
While an employee may have what seems to be “exclusive control” over a ceiling unit, the unit itself is not cord and plug. An electrical disconnect other than a cord and plug cannot be located closer to the employee performing maintenance on the equipment by the employee themselves. Only a piece of equipment that functions using a cord and plug as an electrical source has potential to fall under the exception to the OSHA 1910.147 standard. Locking out ceiling disconnects is crucial for a ceiling unit to be de-energized to a zero-energy state.
Many ceiling units are located in a remote location, typically not easily accessible. However, this does not mean these units cannot be re-energized by another individual. For example, if an employee is working on a ceiling unit, then leaves the area temporarily while the unit is still under repair, locking out ceiling disconnects prevents another employee from re-energizing the unit while it is unsafe to do so. The remoteness of the equipment does not qualify as prevention from the equipment being reenergized.
Ceiling units, especially HVAC units, have unlockable sources of energy. Kinetic energy from a spinning fan blade can cause be dangerous, and even fatal. Exclusive control applies to units that are typically small enough that a limb (or more) cannot be inserted into the unit. HVAC units can be large enough that a person may fit a portion of their body into the path of the spinning fan blade. These unlockable sources of energy are sometimes caused by turning on the electrical source. An individual cannot have exclusive control of an electrical disconnect while working inside of a unit. Thermal energy can also be stored in many different pieces of ceiling equipment. Locking out ceiling disconnects will remove the potential for an unlockable energy source to cause harm to any employee working on (or near) the piece of ceiling equipment.
A letter from John D. Weagraff to OSHA on March 22, 2000 asks if ceiling units fall under the 1910.147(a)(2)(iii)(A) exception for exclusive control. The OSHA interpretation response explains why these ceiling units do not fall under the exception, and that locking out ceiling disconnects is required. The interpretation also goes on to explain that a tag is not a valid substitution for a lock on an energy source point that can be locked out. This holds true in all similar scenarios, even outside of ceiling units. Ceiling units must be locked out and do not fall under the exception of “exclusive control.”
If you have any questions about your ceiling equipment or locking out ceiling disconnects, please feel free to contact us.