The control of hazardous energy is not just a federal government standard, it’s a vital part of your company’s accident prevention program, and most importantly, vital in keeping your employees from becoming a victim of serious injury or even death.
According to the Occupational Safety and Health Administration (OSHA), the failure to control hazardous energy accounts for nearly 10% of the serious accidents in many industries. In 2011, the OSHA Census of Fatal Occupational Injuries Report showed that out of the total 4,693 fatalities, “Caught In” or “Struck by Equipment” accounted for 16% of the deaths.
According to OSHA statistics, the failure to control hazardous energy (OSHA Standard 29 CFR 1910.147) was number five in the top ten most frequently cited standards in 2012. OSHA estimates that compliance to the standard will prevent 120 fatalities and 50,000 injuries each year.
When researching recent serious accidents and fatalities in pallet plants and sawmills, I found three OSHA standards were commonly in violation:
• Control of Hazardous Energy OSHA Standard 29 CFR 1910.147
• Hazard Assessment OSHA Standard 29 CFR 1910. 132(d)(2)
• Equipment Guarding OSHA Standard 29 CFR 1910 Subpart O
As a safety professional, it is not at all uncommon to hear of a serious injury or death from a worker becoming caught in a piece of equipment. An accident investigation will commonly find that the company has a written Lockout/Tagout (LOTO) or control of hazardous energy program in place. Yet, the failure of management to enforce the program and/or provide the required employee training is often the root cause of the accident.
It is also common to find that the company failed to complete a hazard assessment of the workplace. (OSHA Standard 29 CFR 1910. 132(d)(2)
The hazard assessment is the first step in determining what hazards workers will be exposed to both during equipment operation and maintenance. Without the written hazard assessment, you have not identified the hazards that your workers will be exposed to, what engineering controls need to be completed in order to reduce exposures, or what personal protective equipment is required.
The hazard assessment also guides you toward the subjects of safety training required for employees performing the tasks, and once completed, can be an important training tool. You can further analyze hazards by individual task if you complete a Job Hazard Analysis (JHA). As I tell everyone, “If you do not document your work, there is no use doing it.” It is impossible to prove to an OSHA enforcement officer that you have completed the required safety program component, if you haven’t documented it.
See Sidebar 1 to view a sample hazard assessment that I created and use for equipment and operations of my clients. It can be used as is or adapted to your specific needs: The assessment can also be adapted to become part of a JHA as well as a training document.
Each assessment must be dated, and include the person’s name that completed the assessment. As you can see, the assessment is broken into five sections:
• Equipment / Operation
Description
This describes either the equipment or operation to be assessed. The same document can be an assessment form for a variety of operations.
• Limits / Ratios / Setting
This section is to identify settings associated with the equipment. During some equipment operations, the hazards vary under certain tasks or settings. The operation may have minimums and maximums that would be important in assessment or training purposes.
• Hazard Conditions / Areas / Points
This is where the specific exposures can be itemized. This is important for identifying engineering controls, guarding, personal protective equipment, control of hazardous energy and safety training.
• Personal Protective Equipment (PPE) Requirements
Once the hazardous exposures have been determined, and engineering controls have been completed to reduce the hazardous exposures to workers, the PPE required while in the area where this task is performed can be identified.
• Lockout/Tagout or Control of Hazardous Energy
In this section of the assessment, you can identify the equipment specific energy sources, and the device or devices needed for the energy isolation. Many types of equipment have more than one energy source, or a job may have more than one piece of equipment or tool that is involved in the task. For example, a saw will often have an in-feed and an out-feed with a separate power source and point of isolation. You may also have electric, hydraulic and pneumatic (Compressed air) as energy sources related to the operation of one piece of equipment.
When identifying equipment specific energy sources, it’s also a great idea to take a photo of the shut off locations, and points of energy isolation for each piece of equipment as in figures 1 and 2.
The photos can be attached to the equipment’s specific LOTO procedures.
The following is an example written equipment specific LOTO procedure:
The authorized person shall:
• Shutdown the equipment by placing the controls in the off position.
• Notify all affected personnel of the LOTO procedure.
• Document the information on the activity log.
• Isolate the equipment from its energy source by shutting off the power disconnect.
• Lockout/Tagout the energy source by placing a lock and a “Do Not Operate” tag on the power disconnect.
• Complete the information on the tag.
• Eliminate stored energy where applicable.
• Test equipment to verify isolation of energy by cycling the on / off controls.
• Perform the maintenance or repairs.
• Remove all tools and equipment and reinstall all guarding.
• Notify all affected personnel prior to removing the lock and tag.
• Remove the locks and tags from the energy isolating device.
• Check to assure all personnel are clear of the equipment.
• Place the equipment controls in off or neutral.
• Energize equipment.
• Document procedure on the activity log.
OSHA enforcement officers are very impressed when they find that a company has gone to the level of completing and posting hazard assessments and equipment specific LOTO procedures for equipment.
According to OSHA, you need to accomplish three critical activities to ensure employees’ safety when they’re servicing or working near equipment that could expose them to hazardous energy:
• Develop written procedures for controlling hazardous energy.
• Train employees in the procedures.
• Conduct inspections of the procedures at least annually.
LOTO and control of hazardous energy training needs to be provided at the employee’s initial assignment, annually thereafter, whenever changes in procedures occur, when new equipment is placed into service, or in the event of a close-call hazard or an accident trend.
Depending on your workplace, there may be additional standards related to LOTO and the control of hazardous energy. You can obtain free brochures and copies of OSHA standards from your local OSHA office, or online http://www.osha.gov/index.html
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@aol.com.
