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Lockout/Tagout Law Basics: NY Recycler Fights Fines
Safety on the Job: Lock-out and tag-out procedures are fundamental to helping ensure safety in industrial plants; a look at how these procedures can help keep employees working safely.
By Chaille Brindley
Date Posted: 4/1/2006
Federal laws for protecting workers against injury due to control of hazardous energy are nothing new to any legitimate company in the pallet and lumber industries. But these requirements are more detailed than just simply placing a lock or tag on a machine. The details of the federal and state standards are where most companies in the forest products industry run into trouble if they are not in compliance.
Commonly known as lockout/tagout (LOTO), the practice of safeguarding workers from the accidental startup of machinery during repair and maintenance functions is governed by 29 CFR 1910/147 and is administered by the Occupational Safety and Health Administration (OSHA). Industry has been required to comply with the federal LOTO standards since 1990.
Although LOTO has been around a long time, it recently became an issue when OSHA fined Power Pallet Inc. of Amsterdam, N.Y. for failing to comply with LOTO requirements. The company was in the middle of a move when an unexpected OSHA inspection sparked a debate between the recycler and government inspectors. OSHA cited Power Pallet for "willful and serious safety and health violations" and fined the company $120,000. Power Pallet is challenging the fines claiming that they are excessive and do not take into consideration the fact that the company was in the middle of relocating its plant when the inspection occurred.
OSHA’s inspectors allege that Power Pallet failed to develop specific procedures for shutting down machines and preventing them from being powered up during maintenance and repair.
OSHA also claims that Power Pallet did not provide an adequate supply of locks, ensure their use or effectively train workers on the required procedures.
Sam Donadio, president of Power Pallet, said that his company complied with all of the things identified by the inspectors in a timely manner. He said that during the middle of its move Power Pallet had equipment running in two locations. It had to operate some machinery in the new facility to supply customers. Sam said that the new facility did have a LOTO system in place, but it was not complete enough according to OSHA.
Sam stated that he was not aware
"OSHA can walk into most pallet plants and will find that their lock out/tag out programs are lacking," said Sam.
The LOTO can indeed be a complex issue if you do not know all the aspects of the law. This article covers the basics about the federal law and some nuances that companies in the wood industry should consider. Some states, such as California, do have their own unique LOTO requirements. Check state regulations to make sure that the laws in your state are not more severe than the OSHA standard. According to OSHA, compliance with LOTO standards prevents an estimated 120 fatalities and 50,000 injuries each year.
LOTO applies when an employee must remove or bypass a guard or other safety device during service or maintenance, an associated danger zone exists during machine operation or the employee must place a body part into an area of the equipment where work is actually taking place upon the material being processed. According to the OSHA standard, LOTO does not apply when servicing or maintaining cord and plug connected electrical equipment. In those cases, the hazard should be controlled by unplugging the machine from the
Energy sources include more than just electricity. Hazardous energy sources can also include: thermal, chemical, pneumatic, hydraulic, mechanical and gravity.
In most circumstances machinery should be locked out and tagged out during setups, when performing maintenance or troubleshooting and when making repairs. There are two main types of employees when it comes to LOTO. There are authorized employees who perform service or maintenance on machinery. They are responsible for using LOTO to safeguard themselves and others. And there are affected employees who operate machinery or interact with it but do not service or maintain it. These employees are not responsible for implementing energy control procedures.
Effective LOTO protection starts with a good program designed for your operation. OSHA requires that a complete LOTO program includes documented energy control procedures, an employee training program and periodic inspections of the procedures. Energy control procedures should take into account the unique nature of each machine. Some have multiple energy sources, different connection means or a particular sequence for shutting down a machine. A thorough survey of your operation should be conducted in order to identify what machinery/equipment requires LOTO control. This list should be reviewed annually and updated when any new equipment or process is added. Unique procedures should be written for each piece of machinery. Safety consultants can help answer questions and provide feedback about the effectiveness of various protection measures. LOTO procedures must be tested to ensure their effectiveness before being implemented.
Procedures for each machine must include the following steps: (1) preparing for shutdown, (2) shutting down the machine(s) or equipment, (3) isolating the machine or equipment from the energy source(s), (4) applying the LOTO device(s) to the energy-isolating device(s), (5) safely releasing all potentially hazardous stored or residual energy, and (6) verifying the isolation of the machine(s) or equipment prior to
Employees should be trained on the dangers of hazardous energy and LOTO procedures. Affected employees require the least amount of training. They simply need to be able to recognize when a LOTO control procedure is being used and understand the purpose of it and the importance of not trying to start-up or use the equipment with the LOTO device(s) in place.
Authorized employees must at least know the details about the type and magnitude of hazardous energy present at the workplace and the methods required to isolate and control those energy sources, including proper techniques for using LOTO devices.
There are some special circumstances that require unique solutions or extra attention. Some service operations must be performed with the power on. In these cases, the general LOTO procedures will not be used. But the employer must provide effective protection for employees performing such operations.
Shift changes are another special consideration that must not be ignored. Specific procedures must ensure the continuity of LOTO protection during shift or personnel change. Historically, a high percentage of accidents have occurred shortly after a shift change. This is because employees do not adequately communicate what is going on with incoming personnel. Exiting personnel should meet oncoming personnel at the lockout/tagout device. Any important safety information or problems regarding the maintenance/repair should be discussed at that time. Oncoming authorized employees should apply their LOTO devices before exiting authorized employees remove their LOTO devices if possible.
Another reason why some accidents occur is because proper LOTO devices are not applied. OSHA requires that LOTO devices be standardized at a particular operation. Locks must be substantial to prevent removal except by excessive force, such as bolt cutters. Tag means of attachment must be non-reusable, attachable by hand, self-locking and non-releasable with a minimum unlocking strength of no less than 50 pounds. Locks and tags must clearly identify the employee who applies them. Tags must also provide adequate warnings such as, "DO NOT START, DO NOT OPEN, DO NOT CLOSE, DO NOT ENERGIZE, DO NOT OPERATE."
When it comes to applying locks, OSHA generally encourages companies to have a "one person, one lock, one key" practice although this may not be the only way of satisfying the standard in some situations. Companies can have master keys that can be used to remove locks in special circumstances. This should only be done by an authorized employee under the employer’s direction and supervision within the procedures outlined in the company’s OSHA-approved LOTO program.
OSHA requires periodic inspections of LOTO procedures. At a minimum, the inspection must contain two components: an inspection of each control procedure and a review of each employee’s responsibilities under the energy control procedure being inspected.
This article only covers the basics of LOTO. You may need to consult with a certified safety professional or OSHA to get specific questions answered.
Both the National Wooden Pallet & Container Association (NWPCA) and the Canadian Wood Pallet & Container Association (CWPCA) offer safety programs for members. These programs can help provide important information as you develop your workplace safety initiatives.
Keep in Mind
• When two or more authorized employees are servicing a machine, each person must apply his own lock.
• When buying new equipment, make sure it is capable of being locked out. Otherwise, you may have to retrofit the machine after purchasing it.
• Removing fuses is not a substitute for locking out a machine unless the fuse box is locked to provide adequate safety.
• Never loan your safety padlock key to another person. Each employee is responsible for his own lock.
• Ensure that lockout/tagout devices identify the individual users.
• If an energy-isolating device is lockable, locks must be used unless it can be proved that a tag provides employee protection equivalent to that provided through a lockout program. Tags are essentially just a warning device and can provide a false sense of security in many circumstances if used without a lock.
• Do not guess what controls apply to what machines. All disconnects, switches, levers and valves should be clearly marked.
• Stored energy can be just as dangerous as connected energy. Grounding, repositioning, blocking or bleeding may need to be done to secure stored energy. Capacitors, coiled springs, elevated machine members, rotating flywheels, air gas, steam, chemical and water systems are sources of stored energy.
For More Information
• NWPCA’s program includes Web-based training, industry specific handbook and private consultation with OSHA safety expert/attorney. Visit www.palletcentral.com or call 703/519-6104.
• CWPCA’s program includes a safety manual covering Canada’s safety requirements. Visit www.canadianpallets.com or call 877/224-3555.
• OSHA – visit www.osha.gov or call 800/321-OSHA (6742)
• State specific programs – visit www.osha.gov/fso/osp/index.html