Read-aloud huddle
Today, focus on machinery servicing covered by OSHA's general-industry energy-control standard. A stop button is not an energy-isolating device. A motionless machine can still contain hazardous energy. Before covered servicing starts, the authorized employee must follow the equipment's energy-control procedure: shut down, isolate the energy sources, apply the required lockout or tagout devices, render hazardous stored energy safe, and verify isolation and deenergization. If stored energy can build back to a hazardous level, verification must continue while that possibility remains during servicing. If you are not authorized, do not improvise isolation. Pause and involve the authorized employee. This huddle is a reminder, not authorization to service equipment. OSHA 1910.147(b), (c)(8), (d)
The case behind today's question
In a September 23, 2026 announcement, OSHA said ModWash LLC in Sicklerville, New Jersey, failed to lock out equipment before maintenance and did not use energy-control procedures. The release does not report an injury or say workers relied on a stop button. Today's stop-button question is a prevention lesson, not a reconstruction of that case. OSHA announcement
Confirm the scope: The cited standard, 29 CFR 1910.147, excludes construction employment and has other exclusions and exceptions. Confirm which requirements and equipment procedure apply to your task. OSHA 1910.147(a)
Two myths to clear up
- Q: If the machine stops, is its energy isolated? A: No. Push buttons and other control-circuit devices are not energy-isolating devices; isolation physically prevents energy transmission or release. OSHA 1910.147(b)
- Q: Once the lock is on, can servicing begin? A: Not yet. Hazardous stored or residual energy must be rendered safe, and the authorized employee must verify isolation and deenergization before work. OSHA 1910.147(d)(5)-(6)
Plan controls from strongest to last line
Adaptable planning prompts: discuss these options in hierarchy order. OSHA prioritizes elimination/substitution and engineering solutions, followed by safe work practices, administrative controls and PPE. Review choices with workers for feasibility and new hazards. OSHA control-selection guidance
- Elimination: Can a process or design change remove the hazardous servicing exposure?
- Substitution: Could safer equipment or a different process reduce the hazard?
- Engineering: Does the equipment provide suitable physical energy-isolating devices? Raise design gaps for qualified review. A stop button does not meet that definition. OSHA 1910.147(b)
- Administrative: Confirm trained, authorized employees and the applicable energy-control procedure before covered servicing. OSHA 1910.147(c)(4), (c)(7)-(8)
- PPE: Confirm protection needed for remaining hazards; PPE does not replace the required energy-control steps. OSHA hierarchy guidance and 1910.147(d)
Crew discussion and action plan
Adapt these prompts to today's work. Which energy sources and isolation points does the procedure identify? What could retain or reaccumulate hazardous energy? Confirm the site's stop-work and no-retaliation procedures, including whom to contact about an unresolved concern.
- Identify the servicing task, applicable requirements and equipment procedure. Owner: Assign a responsible person together Due: Before planning the servicing work
- Have the authorized employee confirm isolation, stored-energy control and verification steps. Owner: Name the authorized employee Due: Before covered servicing begins
- Record each unresolved gap, assign its correction and confirm how closure will be checked. Owner: Name someone able to implement the correction Due: Agree a deadline before affected servicing begins
OSHA recommends assigning control-plan owners, completion dates and a way to verify effectiveness. OSHA hazard-control planning
Verification question: Who is authorized to verify isolation, and what equipment-specific procedure will they follow before servicing begins?
Close-the-loop question: What gap did we find, who owns the correction, when is it due, and how will we confirm it is resolved before affected servicing begins?
Comprehension check: Does pressing the stop button establish energy isolation? No; a stop button is not an energy-isolating device.
Sources
- September 23, 2026: OSHA cites New Jersey car wash for energy-control failures — OSHA. Accessed 2026-09-24. osha.gov
- 29 CFR 1910.147: Control of hazardous energy during servicing — OSHA. Accessed 2026-09-24. osha.gov
- OSHA: Select controls using the hierarchy of controls — OSHA. Accessed 2026-09-24. osha.gov