OSHA 1910.147 / NFPA 70E 120.5

NIST SP 800-82 Rev. 3, Guide to Operational Technology (OT) Security (advisory guidance, not enforceable code); ASHRAE 135 (BACnet) Network Security / BACnet Secure Connect

BAS controllers must be on a segregated network (VLAN or separate physical network) with firewall protection from general IT traffic. Default passwords must be changed, and access should be restricted to authorized personnel. NIST SP 800-82 provides cybersecurity guidelines for industrial control systems. Unsecured BAS devices have been exploited in real attacks to disrupt building operations and gain access to corporate networks.

OSHA 1910.119(e)(6)

This fails OSHA PSM requirements. OSHA 1910.119(e)(6) explicitly requires that the Process Hazard Analysis be updated and revalidated at least every 5 years. The plant's PHA is now 7 years old and 2 years past the mandatory revalidation deadline. The revalidation requirement exists because process conditions, equipment condition, personnel, and industry knowledge of hazards change over time, even without intentional process modifications. Additionally, incident investigations, near-misses, and new regulatory guidance since the original PHA may reveal hazards not previously identified. The 5-year revalidation is mandatory regardless of whether process changes have occurred.

OSHA 1910.138 / SMACNA Safety Manual

Raw sheet metal edges are razor-sharp and cause severe lacerations. OSHA and SMACNA safety standards require cut-resistant gloves (ANSI A4 or higher) when handling unfinished sheet metal. This is the #1 injury in sheet metal shops.

OSHA 1910.147(c)(2)

OSHA 1910.147 requires an energy isolating device capable of being locked out to be LOCKED out. A tag alone is a warning, not a control — it stops nobody who does not read it. Proximity to the crew is not a substitute; the rule exists precisely because the person who re-energizes equipment usually does not know anyone is working on it.

OSHA 1910.147(d)(6)

OSHA 1910.147(d)(6) requires the authorized employee to VERIFY that isolation and de-energization have actually been accomplished before starting work — by testing for absence of voltage and attempting a normal start. A handle position is an indication, not a verification. Handles break, contacts weld, and the disconnect you opened is not always the one feeding the equipment.

OSHA 1910.147(e)(3)

OSHA 1910.147 requires each lock to be removed by the employee who applied it. Removal by anyone else is permitted only under a specific documented procedure that includes verifying the employee is not in the facility and informing them before they return to work. A master key kept for convenience defeats the single guarantee the standard provides — that your lock is the only thing that can start that machine while you are inside it.