Demystifying OSHA lockout tagout

8. December 2009 by moondog.

Reprinted from December/January 2009 BIC with permission from BIC Alliance.
Written by Keith Davis, President, Application Factory, Inc.

Ten percent of all OSHA violations are related to improper locking and tagging out, which must mean noncompliance translates to a misunderstanding of the code. So, let’s demystify OSHA’s requirements.
Standards are minimum guidelines and there are few exceptions. Lockout tagout (LOTO) is a way of life and, by OSHA definition, an energy control program that employers administer with three distinct components — energy control procedures, education for employees in utilizing
energy control procedures and inspection of these procedures periodically. Put more succinctly:
Develop. Train. Review.
First, develop an Energy Isolation List (EIL). Organizations must identify hazardous energy sources such as electricity or pressure.
A hazardous energy source could be anything that changes in state or position violently enough to cause injury. To identify these
points, review up-to-date piping and instrumentation diagrams or do a physical inspection of your facility. Common industry practice is
to enter these points in a spreadsheet.
Next, appropriate procedures for isolating the energy source and dissipating energy accumulated therein needs to be written. Procedures
do not have to be redundant. For example, if there are multiple isolation points that represent the same type and magnitude of energy then
a single procedure can be referred to for that common type. Conversely, varying conditions dictate varying procedures. Lockout and tagout devices must be written with types of devices and how to place these devices documented. Everything that meets one of the following criteria must be locked out:
• Designed with a hasp or other part to which you can affix a lock.
• Has a locking mechanism built into it.
• Can be locked out without dismantling the device such as a lockable valve cover or circuit breaker.
There are similar guidelines for tagout devices. They have to be:
• Single purpose, i.e., they are only used for energy isolation.
• Durable enough so that they do not deteriorate or become illegible even with corrosive components.
• Standardized according to color, shape and size, such as a red oval with the word “DANGER” in the middle.
• Clear in their instructions to employees, such as, “Do not energize.”
Tag attachments must be:
• Nonreusable.
• Self-locking.
• Nonreleasable with a minimum unlocking strength of 50 pounds.
• Attachable by hand with one-piece nylon cable tie or equivalent, which should observe the same durability standards.
After development of your LOTO procedures, you must train folks to use them.
Communicate clearly to the employee to effectively control hazardous energy. Give hands-on training to cover the placement of LOTO
device and determine who has the responsibility and who has the authority to apply and remove LOTO.
Your training procedures must provide employees with at least the following information:
• How to use the procedures.
• Details on steps to shut down, isolate, block, secure and dissipate energy sources.
• Specific details identifying responsible and authorized parties.
• Details designating the safe placement and removal of lockout/tagout devices.
OSHA requires retraining when there is a change in job assignments, machinery or processes
that present a new hazard or a change in energy control procedures.
Finally, OSHA expects you to self-monitor with periodic review of your LOTO processes and guidelines for the review. There
are three critical review points that inspectors must check for:
• Employees are following the steps in energy controlling procedures with documentation of machines and/or equipment on which
energy control procedures were used, date of the inspection, names of employees involved and the name of the inspector.
• Employees involved have demonstrated that they know their responsibilities under the procedures.
• The procedure is adequate to provide necessary protection.
It is ultimately the employer’s responsibility to certify that the inspectors are performing periodic reviews of procedures.
For more information, call (800) 839-1645 or visit www.applicationfactory.com. •

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LOTO Compliance: Lack Not

9. November 2009 by moondog.

Despite the safety risk and cost of violating OSHA’s CFR 29 Section 1910.147, there are still deficiencies in lockout tagout (LOTO) in the industrial sector. According to OSHA, about 10 percent of all accidents in the workplace are caused by not following procedures of lockout and tagout and as many as 82 percent of the LOTO violations are due to failure to isolate, block and/or dissipate the energy source(s). With so much at stake and clear guidelines, why are there incidents related to lockout tagout?
Lack of documentation
There are many organizations that want to comply but don’t have sufficient information — companies whose operators are tagging their isolation points and writing out a good tag diligently but are not aware of details of what has to be tagged to isolate. This is commonly caused by a lack of documentation or over reliance on senior employees to tell them what to do. It is a common mistake for someone to isolate electricity properly but not isolate other forms of energy like pressure. These incidences occur for a variety of reasons, such as a lack of understanding about what needs to be tagged, or the inevitability of human error, both the result of a lack of documentation of the isolation points.
Countless organizations have not identified all isolation points on their equipment and have not documented these points. A critical tool for documentation of isolation points is an Energy Isolation List (EIL). The EIL is the conductor that orchestrates a properly ordered, complete isolation. Another common document is a Blinding List that provides a list of isolation points that require blinding and details like blind type. Other lists include a Critical Alarms Checklist and a Gasket Staging List.  Setting up these lists properly is vital, as well as keeping them updated as equipment changes occur. As isolation points evolve, so should the EIL. Besides, OSHA requires that employees review their LOTO procedures at least once a year.
Lack of procedures
Some organizations have sufficient information in the form of a well-maintained EIL, but because of a shortage of time or overwhelming number of tags to be handwritten, tagging is handled in a careless, even haphazard manner, destroying the integrity of the process. For instance, OSHA requires at least a date, signature and equipment description to identify employees authorized to manage LOTO. However, frequently this information is omitted.
Another corner-cutting decision is using substandard tags. When a tag is hung for a week, a month or longer, it’s possible the sun and rain will render it illegible if not blank. If OSHA finds blank tags, there will be citations and fines. Not only do LOTO materials need to be durable but tags need to be replaced if hung for extended periods of time. OSHA requires that no tag hang longer than one year, but the reality is most tags are worthless before a year passes.
Lack of training and review
Another 7 percent of the violations cited are due to failure to verify the energy source has de-energized before beginning work. Here is a real-world example. An operator blinds the output of a stream but doesn’t blind the inlet. There is still pressure on the line that results in a release of pressure and potentially hazardous product. The best-case scenario is minor injuries and clean up. Worst case involves injuries and a reportable spill. The bottom line is if the operator is trained and there are written procedures in place about shutting equipment down, incidents are less likely to occur.
Lack of commitment
Last and worst, is downright disregard of procedures or total negligence. Sadly, organizations have operators just write a whole stack of tags, sign them and then go out and hang them, an absolute violation of OSHA’s mandated procedures. There are organizations not locking out or tagging out and are thereby committing the most egregious offense and endangering their employees.
Next month in BIC Magazine, I will discuss demystifying the OSHA regulations. For more information, call (800) 839-1645 or visit www.applicationfactory.com. •

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Safety Facility Management Stats - October 2009, page 18 -21

28. October 2009 by admin.

Lockout/Tagout is a major OSHA-inspection focus. In fact, it’s the #1 most cited violation for general industry. But, rather than focus on the negative aspect of noncompliance and citations, focus instead on this; comprehensive and thoroughly-followed LOTO programs:

• SAVE LIVES – preventing an estimated 250,000 incidents, 50,000 injuries and 120 fatalities annually;

• CUT COSTS – significantly; both lost employee time and insurance costs;

• IMPROVE PRODUCTIVITY – minimizing equipment downtime;

• BEST PRACTICE – being widely adopted across industries and industrialized countries

 

The following are actually specific incidents that happened involving a faulty LOTO system:

Program Development and Procedures

Synopsis of Regulatory Standard: According to 29 CFR 1910.147 (c)(1), the employer is to establish an energy control policy/program consisting of energy-control procedures, employee training and periodic inspections to ensure that the machines or equipment are properly isolated from their energy sources, and rendered inoperative prior to any servicing or maintenance.

29 CFR 1910.147 (c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in locking out equipment. A separate procedure must be created for each piece of equipment, or each group of similar equipment as defined, except for equipment that meets a rigid set of exceptions.

Related Incident & OSHA Citation: October, 2007; OSHA proposed $112,500 in penalties to a large employer for repeat violations, including failure to develop proper energy control procedures.

Less than three months earlier, the same organization was cited for $2.78 million in proposed fines for 42 willful violations of the lockout/tagout standard, including failure to utilize lockout procedures before attempting to clear equipment jams, and failure to provide training to four employees responsible for clearing jams. Tragically, an employee had been killed in a related accident.

Successful Program & Procedure Development: The written lockout policy is your starting point; it establishes the ‘nuts and bolts’ of your overall lockout program. Begin this by over viewing and then documenting your program; continue with machine-specific procedure development, training and periodic inspections. OSHA has a Lockout/Tagout Tutorial on its www.osha.gov website that provides additional advice.

Also see Brady’s Lockout Pro Graphical Lockout Procedure Software for a thorough sample energy control policy that can serve as a guide as you develop your own comprehensive energy control program. However, the overriding benefit of Lockout Pro is that it allows you to create and manage clear & easy-to-follow visual machine-specific procedures for all your equipment.

Energy Control Points

Synopsis of Standards: According to 29 CFR 1910.303 (e) and (f) Subpart: Electrical, all disconnecting means must show the magnitude and shall be legibly marked to indicate the purpose.

ANSI Z244.1-2003, Control of Hazardous Energy, states that all energy isolating devices should be adequately labeled or marked unless they are located so that their purpose is clearly evident. Identification shall include the machine supplied and the energy type and magnitude.

Related Incident & OSHA Citation: November, 2002, OSHA cited a manufacturer for failing to protect workers from electrical hazards that contributed to the death of a worker. The employee was working on electrical equipment that had not been properly labeled and disconnected. OSHA issued a willful citation for failing to properly label electrical equipment, and a serious citation for failing to have adequate procedures in place to render machinery inoperable while maintenance and repair work were performed.

Successful Energy Control Point Identification: Locate and mark all energy control points, including valves, switches, breakers and plugs, with permanently placed labels or tags. Cross reference each label and tag with the corresponding step number in the posted energy control procedure for that equipment. Include information about the magnitude and purpose of the control point as stipulated by OSHA for electrical disconnects and recommended by ANSI for all isolating devices.

Training, Communication & Inspections

Synopsis of Standard: 29 CFR 1910.147 (c)(7) requires an employer to provide training to ensure that the purpose and function of the energy control program are understood by employees … (iv). The employer shall certify that the employee training has been accomplished and is being kept up to date …

Standard: 29 CFR 1910.147 (c)(6) The employer shall conduct a periodic inspection of the energy control procedure at least annually.

Related Incident & OSHA Citation: August, 2007, OSHA conducted an investigation following the death of a fleet mechanic who was pinned between two trucks while performing maintenance on one of the vehicles at the company’s worksite.

“This was a preventable tragedy” stated the director of OSHA’s area office. OSHA issued one willful violation for alleged failure to implement and train employees on a lockout/tagout program to be used when performing vehicle maintenance.

Successful Training, Communication & Inspections: First, establish formal training programs for each of the three categories of employees for lockout: ‘Authorized’, ‘Affected’ and ‘Other’ employees. OSHA provides advice on how to train, and verify that the training is up-to-date.

Programs like Brady’s Lockout Pro includes a training module and employee quiz that can be administered upon completion of your employee training. It also provides a straightforward explanation of the periodic inspection requirements.

Proper Protective Products

Synopsis of Standard: 29 CFR 1910.147 (c)(5) says lockout devices must be provided by the employer, be standardized by size, shape or color, be distinguishable from locks used for other purposes, identify the individual who applied the lock, be durable, be strong enough to prevent removal except by using excessive force, and remain under the exclusive control of the individual who attached them.

29 CFR 1910.147 (c)(5)(iii) says that tagout devices shall warn against hazardous conditions if the machine or equipment is energized and shall include a legend such as the following: Do Not Start … Do Not Operate.

Related OSHA Citation: March, 2007, OSHA opened an investigation after receiving notification that an employee was crushed while servicing a hydraulic press that had been disabled but not protected against accidental energizing by locking out potentially hazardous energy sources.

OSHA issued four willful and 15 serious citations, alleging, in part, that the company failed to control potentially hazardous energy during machine repair or maintenance, and was deficient in having personal identification of lockout devices.

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