Many people are hurt because equipment accidentally starts when someone is conducting maintenance or removing something stuck in a line, or doing some other work on a machine. But these accidents can be avoided.
The Occupational Safety and Health Administration (OSHA) regulates the control of hazardous energy by requiring the proper use of lock/tagout (LOTO) devices. These safety locks keep the equipment from accidentally being turned on when someone is in harm’s way. Proper LOTO procedures are critical to safeguarding maintenance staff as well as equipment operators. And OSHA has started cracking down on employers that require specific LOTO devices and procedures for each machine.
The Standard for LOTO 29 CFR 1910.147, requires that hazardous energy be controlled during service and maintenance activities. These activities include the installation, setup, adjustment, inspection, modification, and routine maintenance or servicing of machines or equipment. Machines or equipment must be isolated from their energy source and rendered inoperative to prevent injury or death from unanticipated, uncontrolled hazardous energy.
OSHA standard 29 CFR 1910.147 is strictly enforced. Since failure to comply with this standard results in a serious violation, the citations for failure to comply can be quite costly, up to $132,598.00. Yes, that’s one hundred and thirty-two thousand, five hundred and ninety-eight dollars.
The LOTO standard is also in OSHA’s top ten standards for violations and citations. Therefore, if and when OSHA enforcement pays you a visit, this is going to be a top priority for their enforcement officers.
It is estimated that the LOTO Standard, when in place, prevents 120 fatalities and 50,000 injuries each year. According to OSHA, employers cited under this standard failed to establish an energy control procedure either partially or altogether, while others were cited for failing to provide adequate employee training, failing to conduct periodic evaluations of procedures, and failing to use LOTO devices or equipment.
Every day, I see workplaces that fail to comply with the OSHA standard. A standard that, when implemented and properly trained, is easy to comply with. Completing the LOTO procedure on a piece of equipment prior to performing repairs takes very little extra time, but failing to isolate an equipment’s energy source can cost an employee’s life. The citations issued at that point mean very little. There is no amount of money that can bring an employee back to life!
The OSHA standard requires employers to complete the following:
• Develop, implement and enforce an energy control program.
• Use lockout devices for equipment that can be locked out. Tagout devices may be used in place of lockout devices only if the tagout program provides worker protection equivalent to that provided through a lockout program.
• Ensure that new or overhauled equipment is capable of being locked out.
• Develop, implement and enforce an effective tagout program if machines or equipment are not capable of being locked out.
• Develop, document, implement and enforce energy control procedures. [See the note to 29 CFR 1910.147(c)(4)(i) for an exception to the documentation requirements.]
• Use only lockout/tagout devices authorized for the particular equipment or machinery, and ensure that they are durable, standardized and substantial.
• Ensure that lockout/tagout devices identify the individual users.
• Establish a policy that permits only the worker who applied a lockout/tagout device to remove it. [See 29 CFR 1910.147(e)(3) for an exception.]
• Inspect energy control procedures at least annually.
• Provide effective training as mandated for all workers covered by the standard.
Comply with the additional energy control provisions in OSHA standards when machines or equipment must be tested or repositioned, when outside contractors work at the site, in group lockout situations, and during shift or personnel changes.
When developing the LOTO program, it’s important that employers not only write a program identifying policies and procedures, but the program also needs to include equipment-specific LOTO procedures. This ensures that the authorized employee completing the LOTO procedure isolates the correct energy sources prior to performing maintenance or repairs. Too many times I have heard of authorized personnel performing a LOTO procedure thinking that all energy sources have been isolated, when in fact they haven’t. We have discussed written programs in previous articles. In this article, we’re focusing on equipment-specific energy source identification, isolation and documentation.
Many pieces of equipment found in the pallet and lumber industries have more than one type of energy source, requiring multiple points of isolation. Having equipment-specific energy source isolation procedures helps ensure that the equipment’s energy sources are all isolated and isolated in the correct location. Most equipment that is powered by electricity will have a main control panel that the operator runs the equipment from. When turned off, the energy source may be controlled for certain components, but other components are still energized. Therefore, the equipment’s energy sources have not been fully isolated.
Employees often become complacent, tired, in a hurry, or even lazy. They may complete a LOTO procedure thinking that they have isolated all energy sources, but it only takes one forgotten energy source to cost someone their life. These are just two reasons why an equipment-specific energy source procedure is so important.
For my clients, I created a form called the “Equipment Specific Energy Source and Isolation Chart. The form lists the following energy sources:
• Chemical
• Compressed gases / Pneumatic
• Electrical
• Hydraulic
• Kinetic
• Mechanical
• Potential
• Thermal
Since compressed air is widely used in all pallet plants, let’s use an air compressor for an example equipment-specific procedure:
• In the form, the energy sources are identified as Compressed Gas / Air, and Electrical.
• The isolation devices required for compressed air are a valve isolation device, a lock and a tag.
• The isolation point for the compressed air is the valve located at the outlet, at the bottom of the tank.
• The isolation device required for this electrical energy point is a lock and tag.
• The isolation point for electricity is the power disconnect located adjacent to the compressor, labeled “Compressor.”
The Equipment-Specific Energy Source and Isolation Chart for the air compressor is complete, and easily understandable (See Chart 1). You may add photos of the isolation points and devices to be even more specific in the description.
I recommend that you have your maintenance or other authorized personnel complete these forms for each piece of equipment and then verify them to ensure the document is correct. With regard to hand-operated power tools, you can bunch them together as long as they have the same energy source, for example, pneumatic and/or electrical.
Once these are completed, they can be placed in a binder as a guide for authorized personnel. This document, like other procedural information within your LOTO program, needs to be reviewed at least annually.
These forms create more precise documentation when utilized for authorized personnel training and guide those personnel in isolating each equipment’s energy sources. This ensures that all energy sources are isolated during the LOTO process and prevents accidental contact with energy.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products’ sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@gmail.com.
