Yes. As a matter of fact, you do need a lock out tag out device in place for changing a ballast.
It would be relatively easy to forget to include this work task in a lock out tag out program. That’s why training is essential. Changing ballasts is a seemingly minor ten-minute task that happens frequently.
However unlike servicing equipment connected to an electrical circuit by a cord and plug, when you change a ballast you are exposed to parts of fixed electrical equipment or circuits. Therefore, the activity falls under OSHA’s Subpart S- Electrical Standard Section 1910.333.
OSHA uses the following scenario (among others) to explain:
‘An electrician is replacing the ballast on a fluorescent light. The electrician uses the light switch on the wall to de-energize the florescent light. He verifies that the light will not work after the light switch has been turned “off’ before changing the ballast. The light switch is located in the room where the work is being performed and is in direct sight of the electrician. The electrician is in a position where he will know if another person tries to operate the light switch. In this scenario, electricians normally work in pairs, where one performs the work while the other stands next to the light switch.
Question 3: Is the light switch under the “exclusive control” of the electrician, or is a lockout device still required to be placed on the light switch?
Reply: OSHA’s Subpart S -Electrical standard at Section 1910.333 applies to this question because it involves an employee exposed to contact with parts of fixed electric equipment or circuits. Unlike Section 1910.147, the standards in Subpart S do not include an “exclusive control” exception. Instead, Subpart S standards have their own lockout and tagging requirements for the control of hazardous energy. Specifically, Section 1910.333(b)(2), Lockout and tagging, provides that “…the circuits energizing the parts shall be locked out or tagged or both in accordance with the requirements of this paragraph …”
In the scenario you describe, the light switch may be activated while work is being performed, as the work area is not restricted to others. Moreover, such activation can occur prior to the worker advising another entering employee that electrical work is being performed. Thus, the electrician (exposed worker) replacing the ballast would not be protected from the existing hazard designed to be guarded against (e.g., electrical).’
Does this seem excessive to you? If so, consider the death of a Jersey City Medical Center employee who was changing a ballast without a lock out tag out device in place and was shocked. He fell off his six-foot ladder and later died from his injuries.
OSHA investigated and cited a willful violation because employees were required to change ballasts without lock out tag out training. They were also cited with serious violations, and the proposed penalty is $174,593.
Lock out tag out programs are important to worker safety.
Now may be a good time to review your worker safety trianing program to ensure it includes all work tasks and equipment as required by OSHA. Need help? Learn more about our Safety Services Programs and contact us now to speak with our staff today.