June 26, 2026 The Minor Servicing Exception Explained: Avoiding Pitfalls in LOTO Compliance

Description

OSHA’s Lockout/Tagout (Hazardous Energy Control) Standard remains one of the most frequently cited—and most misunderstood—requirements in manufacturing. While there are many compliance traps in the LOTO standard, few concepts are as challenging as understanding and correctly applying the minor servicing exception (“MSE”), which allows manufacturers to perform certain limited tasks—such as clearing small jams, adjusting guides, lubricating components, or making minor tooling changes—without fully implementing energy control procedures. This exception is intended for activities that are closely tied to normal production operations and can be completed quickly without exposing employees to significant risk. However, determining whether a task qualifies is not always straightforward, particularly when evaluating whether it is truly “routine, repetitive, and integral to production,” as required by the standard. 

In practice, employers frequently misinterpret these criteria, either applying the exception too broadly or overlooking key hazards. Even when tasks appear minor, if they are not performed regularly, follow a predictable pattern, or are essential to the production process, the exception may not apply. Even when they identify tasks that fall within the MSE, manufacturers often struggle to implement alternative protective measures—such as safeguarding, safe work procedures, or presence-sensing devices—that are sufficiently effective to protect employees during these tasks. 

In this webinar, OSHA defense attorneys Aaron Gelb and Mark Ishu will be joined by Ted Sberna, Lead Consultant at White Horse Safety Inc. and member of the ANSI B11 machine guarding standards committee, for an informative discussion intended to clarify regulatory expectations and provide practical guidance for evaluating when the minor servicing exception applies and how to ensure worker safety when it does. 

Participants in this webinar will learn: 

• How OSHA defines and interprets “routine, repetitive, and integral to production” in the context of the minor servicing exception 
• Practical examples of tasks that typically qualify—and those that do not 
• Common compliance pitfalls and misconceptions that lead to improper use of the exception 
• How to conduct a defensible hazard assessment to determine whether full lockout/tagout is required What alternative protective measures are considered “effective” and how to implement them in real-world operations

Presented by Conn Maciel Carey, LLP