Minor Servicing & Alternative Energy Control

OSHA’s lockout/tagout rule says to lock out machines before servicing them. But it also has a narrow exception for minor servicing during normal production, such as quick tool changes or routine adjustments, when workers use alternative measures that give effective protection. The exception is easy to misuse, and misuse is a leading cause of amputations.

• General Industry
• Maintenance
• Safety Managers

What the rule says

OSHA’s control of hazardous energy standard (29 CFR 1910.147) covers servicing and maintenance of machines. Under the scope section, minor tool changes and adjustments, and other minor servicing activities that take place during normal production operations are not covered by lockout/tagout if the work is:

• routine,
• repetitive, and
• integral to the use of the equipment for production,

and the work is done using alternative measures that provide effective protection. If the work doesn’t meet all of these conditions, the full lockout rules apply. See Lockout/Tagout. Construction work generally follows different rules. Check your standard.

What might qualify

• Clearing a jam or a minor stoppage that happens repeatedly during production, if the method is safe. See Clearing Jams.
• Changing a blade, die or tool that is part of the normal production cycle.
• Cleaning or lubricating certain machines during production, where it can be done with safe tools and methods.
• Adjusting guides, sensors or feeders in normal operation.

These examples depend on the machine, the task and the measures used. The employer must be able to show that the task is routine, repetitive and integral, and that the alternative protection is effective. A task isn’t “minor” just because it’s quick.

What does NOT qualify

• Repairs, troubleshooting, major adjustments, rebuilds and other work that isn’t routine or repetitive production work.
• Any task where stored energy (springs, hydraulics, gravity, air) could release and injure someone.
• Work where the alternative measure is just “be careful,” “turn it off at the stop button,” or “use a tag.” These are not effective protection by themselves.
• Work that is unusual, infrequent or beyond the training of the operator.
• Work on machines that start automatically or are controlled remotely.

Alternative measures that can work

Alternative protection must be at least as effective as lockout for the task. Examples include:

• Interlocked guards that stop the machine when opened, with no way to bypass them. See Machine Guarding and Safeguarding Devices.
• Two-hand controls, presence-sensing devices, light curtains and similar safeguarding devices that keep hands out of danger.
• Hold-to-run, jog or inch controls at reduced speed and force, and under the operator’s sole control.
• Remote or tool-based methods, such as hooks, tongs and long tools, that keep the worker’s body out of the danger zone.
• Machine design that allows the task to be done from outside the guarded area, such as an access door with an interlock and a safe position.
• Emergency stops, a lockable disconnect within easy reach and other layers where needed. See Emergency Stops.

Where alternative measures don’t clearly give equal protection, use lockout. ANSI Z244.1 gives guidance on this approach. See ANSI Z244.1: Lockout.

Common mistakes

• Calling a task “minor servicing” to avoid lockout because it is inconvenient.
• Reaching in to clear a jam while the machine is “just stopped,” with energy still connected and no guard interlock.
• Bypassing interlocks, taping down sensors or jumpering switches.
• Relying on the stop button, a tag or a verbal “I’ve got it” as the only control.
• Letting a quick job grow into a longer repair without switching to lockout.
• Not training operators on what is allowed and what isn’t.

What employers should do

1. List the tasks done during normal production that people call minor servicing, for each machine.
2. Assess each task: is it routine, repetitive and integral? Could a body part reach a danger zone? What energy could move? Use a job hazard analysis. See Job Hazard Analysis.
3. Choose and document the alternative measures for each approved task. Write them down, with the machine, the steps and the safeguards.
4. Test that the measures work, such as interlocks, and inspect them regularly.
5. Train operators on the approved tasks, the alternative measures, and the rule that anything else requires lockout. See Training Requirements.
6. Review after incidents and near misses, and when equipment or processes change. Update the list. See Incident Investigation.
7. Audit the program with periodic inspections of procedures. See Group Lockout.

What workers should do

• Know which tasks are approved for alternative methods on your machine, and use exactly the methods that apply.
• If a task isn’t on the list, or the situation is different, stop and lock out.
• Never bypass a safeguard. If one isn’t working, report it and tag the machine out of service. See Safety Culture & Stop Work.
• Ask questions if you aren’t sure. You can contact OSHA at 1-800-321-OSHA (6742). See Worker Rights.

Minor servicing checklist

• The task is routine, repetitive and integral to production
• It is on the employer’s written list for this machine
• Effective alternative measures are in place and working
• No guard is removed and no body part enters a danger zone while energy is on
• I am trained on this task; otherwise I lock out

Last updated: October 4, 2026