Archive for the ‘Article’ Category

A Time to Destroy, and a Time to Rebuild. A Time to Isolate, and a Time to Restore.

Monday, August 11th, 2014

In CFR 29 1910.147, OSHA pays a great deal of attention of isolation. We are clearly told what to do with breakers, valves, etc. Clear instructions surround the acts of dissipating stored energy, and the act of locking devices to be sure that stored or potential energy cannot be released. In a previous article, I made the observation that as the experience and sophistication of isolation teams has grown, new guidelines and procedures have evolved and have been created to further ensure the safety of staff working around an isolated, or locked out, system. Such advancement towards excellence is typical in mature industries like the petrochemical sector. These advancements represent many facets of the isolation activity, some maybe vaguely addressed in the OSHA regulations, some maybe not addressed at all. In this article, I’d like to discuss a topic that OSHA covers, but represents another area where the regulations could be interpreted as too vague, or maybe even incomplete (apologies to my friends at OSHA). That topic is the act of restoration, or when a system is reenergized. As with isolation, there are plenty of opportunities for diligence and advancement of techniques above and beyond the OSHA regulations. Excellence is always available, and actively sought after as corporations seek to protect the human asset, as well as the hard assets of their productions systems. So, let’s entertain a bit of my obsessive compulsive nature and get all OCD on restoration.

Restoration is in some ways an activity very similar to isolation, but in other critical ways, utterly different. The overly simplified casual observation is that we flip the isolation list over, go backwards, and do the exact opposite thing to each isolation point. That is, if I started by turning off the local switch, the last thing I do in restoration is turn that switch on. If I locked a certain valve closed, when I reach it in the process of restoration, I open it. This act of “undoing” the isolation is in many cases just fine. But, as we all know, the devil is in the details and the true hazards lie in the unusual or unexpected situations. The reality is that a minority of injuries occur around properly isolated equipment. The greatest danger exists in the time when things are changing, i.e., electricity again begins to flow, or inventory again begins to move through the system. If we are to be so diligent and obsessed with proper behavior during isolation, then it only follows that we would exercise that same level of care when we reenergize the system. In my humble opinion, this time represents and even greater opportunity for the unusual or unexpected to arise. So, let’s examine the disparities from isolation that are frequently at work in these moments.

In my work of analysis and design of LOTO automation systems, I am fortunate to work not only with some super sharp guys in the petrochemical industry, but also in other completely unrelated but similarly mature and dangerous industries. One recent discussion I had was with an HSE manager at a major pharmaceutical company. The guy was a guru, or maybe just suffering from occupational OCD like me. But, when we discussed the format of his isolation list, I was amazed at the detail the guy employed. For instance, OSHA clearly states that you communicate with affected parties when isolating systems. This guy actually had a sign off on his report for informing affected parties. The overall effect was that his isolation checklist read just like the regs. I know some people in other industries that would scoff at the overly detailed form (especially those in the field that don’t want to seek a proprietor’s signature after informing the person in the far corner), but in my myopic view, it seemed appropriate if not… excellent. And as happens frequently, my brain started squirming like a toad. Who is to say that locking a valve is a more important portion of the regulations than informing the affected parties? If they are of equal weight, why shouldn’t they be clearly documented and signed off upon? Anyway, as usual, I digress. We’re discussing restoration here, right? The reason I got on the topic of my pharmaceutical industry friend is that his isolation report went through all the usual steps, and then also included a restoration checklist, completely independent of the isolation list. Again, this was new to me, certainly not something I frequently see in the petrochemical industry. Many times an Isolation List will include a restoration column, but since they are part of the isolation report, and therefore in isolation order, they do not reflect the appropriate order for restoring. As we discussed the list, it brought back to mind a lengthy discussion I had with a high level safety guy in a little outfit I like to call the largest oil company in the world. His beef was: how do we handle the unusual, and even more difficult, the unexpected? Uh-oh. Here goes my brain again.

Since we are getting a little conceptual here, let’s start with definitions to provide clarity of my setting. For the purpose of this article, let’s say the unusual can be distinguished from the unexpected with one point: the unusual can at least be predicted and, therefore, documented in advance. The unexpected differs in the sense that it cannot be predicted and therefore must be discovered in the field before anybody gets surprised and as a result, injured. Very different situations, but both potentially threatening to people and equipment. Let start with the unusual.

It is common practice to document not only the isolation position of different of different valves and breakers, but to also document the “in-service” or production position of the various isolation points. This is where we vary from the behavior I mentioned earlier, where, in the act of restoration, every point is simply placed in the opposite position of the isolation position. This may not be appropriate. Let’s consider a bypass valve. In my work with a hydrogen supplier of a major refinery, I was told of a situation where a young buck did exactly this. However, there was a bypass valve in the critical path. The bypass was closed in the isolation, and it was supposed to be closed in production as well. When they restored, he opened the bypass valve, effectively circumventing the control valve, and well, you can imagine the adversity that ensued from there. This situation is unusual, but predictable. This is why you will frequently see a document called a “valve line up” that details production positions for the entire flow path. Another example of unusual would be a difference in order instead of position. For instance, what if the staff needs to turn on the motor before opening all valves just to be sure it will run? Not to sound judgmental, but this is information that should be communicated to the staff in the field. What better place to do so than on the restoration checklist? So, now that we have that situation handled, let’s move on to the more difficult situation, that is, the unexpected.

To properly examine the unexpected, I will first describe a real-world example. My friend with the massive oil company brought up a situation where, during a turnaround, isolation had been properly executed and the work had been completed without incident. However, no one was able to know that behind a certain blind (for readers unfamiliar with the terminology, a blind is a metal plate covering an opening in the product flow, also sometimes called a blank), a valve had failed during the turnaround and had begun to leak. The unknown and extremely dangerous condition here is that a significant amount of inventory had gathered up behind the blind and was sitting there ready to spill when the blind was unbolted. This could result in different situations. Best case, a reportable spill of chemicals. On the opposite end of that spectrum, it could cause a lethal flash fire in the immediate proximity of multiple workers. I feel like this horrifying example brings to light the gravity of the situation and the reason I have been rambling through all of this so far. How are we to expect the unexpected? How do we detect this unknown, yet incredibly dangerous situation? My opinion is, we execute a mundane procedure that is done frequently in industry. I humbly suggest a Job Safety Analysis.

Job Safety Analyses are so common in the industry that I will not bother to go into great detail. Let it suffice to say the JSA is the walkthrough of a jobsite that identifies issues in advance and prescribes safe work behavior in advance. The problem is, they are commonly only executed before a job. I respectfully submit that an entire new JSA be executed before restoration occurs. It is easy for me to say this; I am not a person on the ground. However, in my limited experience, I cannot conclusively say how else you would detect and react to these unexpected situations. I doubt anyone would question the motivation here. The short of it is, everyone wants to go home. What better justification does a safety manager need? Whereas I would normally end my blog with an invitation to check out and see how our software can solve the problem, this time, we’ll just skip that. We are discussing a behavioral matter here, and no software can handle that.

Corporate Tagging Requirements Gradually Eclipsing OSHA Requirements

Thursday, October 31st, 2013

As we work with companies in their LOTO automation efforts, we are seeing many new increases in tagging requirements.  But, whereas OSHA was the reason that we originally started this endeavor, now we are seeing many more tag types coming into play, none of which are OSHA required.  As corporations become more concerned with employee safety, they are seeing opportunities to shore up weaknesses in the OSHA guidelines that result in an even safer workplace than OSHA envisioned while authoring CFR 1910.147.

One of our customers, a specialty chemical company, has implemented a new tagging requirement called “Verification Tags”.  These green verification tags are placed on every isolation point, on top of the OSHA-required LOTO tag.  It’s a safeguard to be sure energy isolation has been accomplished and reviewed carefully.  Their primary green color provides an easy visual reference (a “green light”, if you will) indicating that the equipment is safe to work on.  This doubles their tag volume, but also provides a very effective check against failure to isolate.  OSHA has nothing to do with this requirement.  This tagging guideline came down from the ivory tower, resulting from an incident that occurred years ago.  These tags contain different information from the LOTO tag, and if the LOTO automation system is not prepared to produce them, they represent an onerous opportunity to handwrite a large volume of tags.

Another one of our customers uses different colored LOTO tags depending upon lockout authority.  That is, if an operator locks out a device, a white LOTO tag is applied.  If an electrician locks out an isolation point, a red tag is applied.  If a contractor locks it out, a blue tag is applied.  Now, the tagging system must segregate isolation tags and lists by task, or, as in the event of a union shop, by trade.  If the LOTO automation system is not prepared to handle this, you find yourself in situations where operators (as the company men) are automated, but contractors are not.  This results in inconsistent levels of safety and efficiency in the facility.

A third new tag type we have seen implemented happened at a massive oil company.  It was noted that in situations where process equipment is opened, and inventory is exposed to the atmosphere, the danger level is elevated significantly.  The fix for this situation was to hang another tag on every spot where these break-ins to the process stream would occur.  The oil company called these tags OPE tags (for Opening Process Equipment) but we are seeing this behavior in many companies, sometimes called “break in” tags or “line break” tags.  This is probably the second most common tag type we see being used in the industry today.  This one presents a much more difficult tagging scenario.  Whereas our isolation points are fairly standard, these break-ins change frequently, if not every single time a piece of equipment is locked out.  This requirement for flexibility makes the break in tags the most difficult situation to automate.  It took us nearly a year to perfect the method.  In the end, it involved more data management than tagging technology in order to maintain user-friendliness while properly handling the requirement.  Ultimately, we nailed it so effectively that we made real fans within the massive oil company, which is a good thing.

OSHA got us all started with this tagging behavior, but now the industry is self-managing itself, which is pretty much always for the best.  Corporate conscience and behavior has moved beyond what was compelled by law, and now has coalesced into a much safer culture.  All the talk of going home every day is not just talk.  Every day, the industry gets safer, without the government pushing us any further.  For more information on a LOTO system that can handle evolving tagging requirements, visit


LOTO Automation in the Midstream Market – Throughput vs. Production

Thursday, September 26th, 2013

Most of my experience in the petrochemical industry is in the midstream market, from years of providing operations and regulatory programming to the pipeline division of one of the major oil companies.  The mindset in midstream is very different from downstream, although they also go to lunch as early as they can.  Behavior in the midstream market, like in the downstream market, is driven by revenue generation.  However, the revenue generation method is drastically different.

In the downstream market, raw materials go in one side of a processing unit and finished goods come out the other side.  The raw materials are a cost of goods sold, and the sales of the finished goods represent the revenue.  If the ratio between these two numbers is good, then profit is generated.  Market forces may demand more or less of the product, but the reality is that in downstream, it is all about production, the act of completing the processing actions on sufficiently large quantities of raw materials to meet market demand, hopefully at a profit.  Obviously volumes can vary wildly but the overriding truth is that the unit is producing or not producing.  If no finished goods are produced, then it is guaranteed that the unit is not making any money.  The implication this has on LOTO is that the lockout scenarios can be oversimplified as two conditions: stop and go.  The benefit of LOTO automation becomes clear since the time to lockout is reduced.  That is, hurry up with the stopping so we can get back to going.  This line of thought breaks down in the midstream market.

In the midstream market, there are two major revenue sources: storage and throughput.  Storage is the act of occupying space in tankage.  That sounds simple, but thanks to API Volumetric Analysis calculations for things like temperature correction, shell vessel expansion factors, and floating roof corrections, it is not all that simple.  But the reality is that if there is someone else’s product in our tank (the third-party “for hire” scenario), we are making money per barrel per day.  Or, if our product is in our tank, we are at least utilizing our asset, and it can be considered “in production”, even if in use by the internal customer.  LOTO situations apply, but that is not where the midstream LOTO complexity can be found.  The real complexity of LOTO in the midstream market is when we begin to affect throughput.

Another significant revenue source in the midstream market is throughput.  Renting storage in a tank farm can make money, but most tank farms also have a terminal capability, that is connectivity between multiple modes of transportation in one tidy spot.  So, my trucks and railcars can come in from West Texas, and get unloaded at the terminal’s racks that are connected to a pipeline that services my refinery.  The product may or may not get buffered into tankage.  Either way, the terminal is providing this connectivity, which is typically billed on “throughput”, or the number of barrels that go through the connections.  When I am making a few cents on each barrel that goes through my terminal, I want to be sure that the maximum amount is going through at all times.  The product coming in is not raw material other than a physical presence.  The product coming out is not a finished good, other than being delivered to a desired location.  This is more of a service-based revenue than a manufacturing-based revenue, and this is what sets midstream apart from downstream.  The desired lockout scenario now is: keep going and never stop.  It may sound impossible, but all you need is a network of piping systems that provide multiple paths through the terminal.  For a basic example, let’s look at a smaller network: a piping manifold.  An oversimplified explanation of a manifold would be a crisscrossed set of pipes with valves at the intersections.  By opening some valves and closing others, you can come up with many different throughput flows.  There may very well be multiple paths between the same input and outputs.  So now, when we lock out a valve, we have the ability to open others and maintain throughput.  Flow patterns are typically named by the systems or products they serve, so our choices of open and closed valves could be described as maintaining throughput for “tank system 110” or maybe “crude”.  This “always on” methodology is where LOTO automation can succeed, or utterly fail.

As always, the devil is in the details.  When I am maintaining flow to tank system 110, then I have most likely closed off other valves that represent other flow, let’s say tank system 215.  The opposite is also conceivable.  So, before I isolate a valve in a manifold, I review what flow is critical right now (let’s say today it is 110 system), and attempt to lockout in a manner that preserves throughput on that flow (110 system).  When I lockout the same valve tomorrow, tank system 215 may be the critical flow path.  Now I am locking out the manifold in a completely different method to maintain today’s critical flow.  These two very different scenarios are both designed to facilitate work on the exact same valve.  It is a complicated concept, but I can assure you there are operators in the midstream market that evaluate situations and make these decisions off the top of their heads every day.  For LOTO automation to work in the midstream market this complexity must be handled or the whole process falls apart.  This key flexibility can be handled in a very precise and easy-to-use manner, yet it is commonly overlooked in packaged and internally developed LOTO systems.  If you would like to learn more about a comprehensive automated system, request information at

LOTO Automation in the Upstream Market – Gimme a “P”! …but not an “E”

Tuesday, August 20th, 2013

Whereas LOTO automation has clear benefits in many phases of the downstream and midstream markets, upstream is simply a different animal.  Exploration and Production (E&P) are the two most commonly used descriptions of the upstream market.  LOTO has implications on Production, but really plays a much smaller role in the world of Exploration.

Exploration can be oversimplified as the act of finding the natural resources that can then be lifted from the Earth and used as raw materials in the oil and gas industry.  Granted, through the years environmental and safety regulations have altered the complexion of the upstream market.  Gone are the days when a broken down school bus full of roughnecks rattled up in a cloud of dust and got to drilling.  Now, satellite controlled horizontal drilling rigs reach out and cover huge areas with a minimum of human involvement.  Furthermore, energy isolation issues are very different in a scenario that starts and ends in 30 days or less, and OSHA realizes this.  In OSHA’s energy isolation regulations, 29 CFR, Standard 1910.147, right at the beginning it is stated “This standard does not cover the following:” and the fifth and last item in that list is “Oil and gas well drilling and servicing.”  So, if 1910.147 does not apply to drilling rigs, then us too-smart-for-our-own-britches LOTO automation guys need to pack it up and get out of the oil patch.  And take yer fancy tags with you!  Well, that is not quite the case, since we still have the production portion of Exploration and Production.

In the event that exploration succeeds, and the well begins to produce, then we have resources being lifted from the ground.  Now what?  That’s where gathering and extraction come in.  I recently became acquainted with a guy who works on the northern slope of Alaska in a massive gathering and extraction facility.  They have multiple pads with maybe dozens of wells on each of them, with each well being pumped into a gathering facility.  Downstream from gathering, liquids are separated from gasses, and distinct products (water, crude, condensate, natural gas) are extracted.  Whereas the guy on the drilling rig wants his process to end very quickly (hopefully with a producing well, not the cursed dry hole), the guy on the gathering and extraction facility wants the wells to keep producing forever.  This longer-term endeavor brings into play the oldest profession in the world: maintenance.  What, were you thinking of something else?  And of course, where there’s maintenance, there’s a whole lot of LOTO.  So, here we are, unpacking our bags and pulling our fancy tags out again, hoping to save the huddled masses by reducing the manual effort of handwritten LOTO with our high-falutin’ automation systems.

Now those fancy tags better be able to withstand -40 degree temperatures with a 50 mph wind.  My friend on the northern slope says they are doing fine so far.  Not that I’m going there to check them out, I’ll take his word for it.  I’m from Texas; I can barely handle San Francisco.

DangerTags Hydrocracker Case Study

Wednesday, June 26th, 2013

Case Study: Automation of LOTO Saves Time, Money and Streamlines Processes for Turnarounds and Maintenance – February, 2013

A major oil company was faced with a turnaround in their light oils complex. The project was a Herculean task not only because it required changing every gasket, nut and bolt but also because of the massive size of the facility. Because of the sheer size of the project, the refinery leadership team knew there were opportunities to reduce costs that were more significant than usual.

They identified the manual handwritten processes surrounding Lockout/Tagout (LOTO) as an opportunity to save time and money by introducing efficiency through automation. Their LOTO processes were good and effective but just too costly and time consuming, especially when faced with the prospect of over 10,000 handwritten tags.

By their approximation the fastest time a tag could be handwritten was fifteen seconds; essentially equating to 80 man hours to write the required tags, in the least. Given the distractions that the two “tag writers” would face, they estimated that handwriting tags would require two men for two weeks, resulting in a labor cost over $5000.  An ancillary issue was the legibility of the handwritten tags, which could result in, as best case scenario, poor field communications or, worst case scenario, a safety issue.

After soliciting input from their facilities worldwide and perusing the market for all methods of LOTO automation, the company arrived at the conclusion that DangerTags represented the best the industry had to offer. DangerTags is an automated LOTO system that not only reduces labor but uses advanced materials to solve every facet of the problem the oil company faced. The final question was: could they implement DangerTags quickly enough to benefit the turnaround?

The implementation of DangerTags consisted of three tasks.  First, the database had to be populated with all of the unit’s isolation points, i.e., breakers, valves, etc.  Second, the oil company’s EIL format had to be built into DangerTags.  Finally, the users had to be trained on how to use the application.  The company’s implementation team worked with the technical staff at the Application Factory to decide on the best way to accomplish these tasks.

To populate the database, it was decided that the team would leverage their existing lockout lists in combination with the spreadsheet import wizard in DangerTags.  Spreadsheet macros were custom developed to convert the company’s Microsoft Excel-based lockout lists into the DangerTags’ import template format. Once the lists were converted to the DangerTags format, the import wizard in DangerTags allowed the oil company’s operators to quickly and easily populate the database of isolation points.

Very early in the project, it became obvious that it was easier for the programmers at Application Factory to make DangerTags output the company’s EIL format than it would be to get one of the largest corporations in the world to change their corporate safety documentation.  So, the company opted to have Application Factory add their EIL format to the system for more customized output.

Once the database was populated and verified, it was decided that training would occur in the refinery, on company equipment, using their freshly-imported live data.  After the half-day class, the oil company’s turnaround team was prepared to start printing tags and lockout lists.

Over 10,000 tags were printed in a matter of hours instead of weeks, on tagging materials far superior to the refinery’s previous standard. DangerTags’ tags are waterproof, U/V resistant, and completely legible, therefore reducing exposure to OSHA violations and improving field communication. As a bonus, they are barcoded for field scanning and verification.

The entire DangerTags implementation, from database population to tag printing, condensed down to less than two weeks. Essentially DangerTags was implemented, including training, in less time than it would have taken to hand write tags.

After the turnaround was successfully completed, the light oils complex had a system in place that continues to maintain and produce LOTO documentation in the same automated fashion. The long-term effect is a combination of increased safety and lowered expense.

DangerTags is a software system developed by Application Factory, Inc., a software development firm located in Beaumont, Texas, providing custom and packaged solutions to the petrochemical companies of the Fortune 500. DangerTags is distributed by Total Safety, the world’s premier outsourced provider of integrated safety and compliance solutions.

For more information go to,, or call Keith Davis, President, Application Factory, 800-839-1645

Click & Print Technology Streamlines LOTO Processes

Tuesday, January 5th, 2010

From the previous two lockout tagout (LOTO) articles published in BIC, we’ve outlined how OSHA LOTO regulations including documentation, training and review, can be so onerous that one could spend a few hours a day every day doing some task related to LOTO. However, and as a result of the OSHA standards, the industry is adopting technology to increase efficiencies, lower LOTO costs and increase safety. Read here how the application of well-thought out technology can streamline your LOTO processes while also benefitting your bottom line.

Reducing Labor
Labor represents one of your most substantial expenses so anytime you can reduce clerical processes fulfilled by high-dollar people you do it, right?!  An automated system that prints tags not only removes the labor of handwritten tags but given the proper controls can also mean LOTO can be accomplished by less senior, less costly people. We all know a common adverse side effect of the labor intensive nature of LOTO is that highly paid operators spend a  great deal of time doing the clerical task of handwriting tags.  When energy isolation list are organized in a hierarchical database with the input of senior people, even a novice can go and produce the tags in a “click and print” or automated system.

Database Driven Automation
The key to reducing labor and automating LOTO is contingent on a database-driven system. Key points of setting up database are the accuracy of isolation points and completeness of ancillary information like gasket and blind types as well as procedural information like order in which isolation points are locked and tagged out according to standard operating procedure.  This all dictates your LOTO process.  When information is stored in a word document or even a spreadsheet versus a database, it is much more difficult to search and review information and laborious to manage and change.
Therefore the key to implementing an automated LOTO system is to create a database of your isolation points. This database should: 1) be set up by the people dealing with the equipment every day, like senior operators, 2) reviewed by multiple parties and really everyone involved in the LOTO processes – operators, maintenance and supervisors, 3) be reviewed regularly and on a schedule.
Effectively your database of isolation points is a living document that not only requires review for ongoing safety of employees but per OSHA regulations must be reviewed no less frequently than annually.

Reducing Materials Cost
The industry standard employs tags that are insufficiently durable requiring costly brass grommets or pieces of leather in order to add strength to the tag. Additionally, weather, wind and sun render these tags illegible and in violation of OSHA.  So to combat the elements, some organizations use hard plastic tags, which are even more expensive. These tag types are costly and can’t be reused. Therefore proper tag choice is imperative.  By selecting the right materials that are chemical and sun resistant as well as tear resistant to alleviate the need for all the back-up strengthening devices, cost is lowered.  There are tags that exceed the 50-foot pound pull requirement that OSHA dictates for cable ties. These tags are also UV, chemical and heat resistant and absolutely water proof. In large quantities these tags typically cost 40-60% less than the grommet, leather or plastic enhanced tags.

Reducing Liability
Potentially, OSHA violations resulting from improper LOTO, or worse, safety incidents, injury to or death of an employee, can be your biggest expense. If a LOTO system is automated, powered by a database for click and print execution instead of handwritten processes, utilizes durable tags that meet OSHA standards even for long-term tagging, the opportunity for human error and material failure is minimized, thus reducing your expense and liability.

Comprehensive applications provide turnkey processes that support all activities of tagging, initial data collection, reporting, review and day to-day tagging activities, which is why the industry is moving from handwritten, time-consuming and costly processes to click and print.

Demystifying OSHA lockout tagout

Tuesday, December 8th, 2009

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 •

LOTO Compliance: Lack Not

Monday, November 9th, 2009

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 •