Demystifying OSHA lockout tagout

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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