Don't Be Tripped Up by LOTO

When a worker is injured, his or her average time lost for recuperation is 24 days, according to OSHA.

• By Jerry Laws
• Jan 01, 2013

Spend a few minutes reading the posted summaries of OSHA enforcement cases and you'll see many companies are cited for lockout/tagout violations, repeatedly in some cases.

Uretek Archer LLC, identified in a November 2012 OSHA news release as a urethane coating and laminate fabric manufacturer in New Haven, Conn., faced two repeat violations and $60,000 in proposed penalties for allegedly failing to develop, document, and use methods for controlling potentially hazardous energy when employees performed maintenance work on equipment, as well as allegedly failing to conduct annual inspections of energy control procedures. Uretek Archer was cited for similar violations in 2008, according to the release, which said an inspection by OSHA's Bridgeport Area Office found the company had no LOTO procedures in place while workers cleaned machines.

The OSHA general industry standard, 29 CFR 1910.147, explains how to lock out machinery or equipment so hazardous energy –- from electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other potentially hazardous sources -- cannot be released. Several other standards require employers to control hazardous energy, including standards applying to construction, longshoring, marine terminals, pulp and paper mills, and electric power generation, transmission, and distribution.

There are additional requirements beyond the necessary, machine-specific procedures for energy control, as OSHA explains in its helpful online LOTO information:

• Employers must train workers to ensure they know, understand, and can follow the applicable control procedures. "Workers must be trained in the purpose and function of the energy control program and have the knowledge and skills required for the safe application, usage and removal of the energy control devices," according to OSHA.
• All employees who work in an area where energy control procedures are in use must be instructed in the purpose and use of those procedures and about how attempting to restart or re-energize machines or equipment that is locked or tagged out is prohibited.
• Employees authorized to lock out machines or equipment and perform maintenance operations must be trained to recognize hazardous energy sources in the workplace, the type(s) and magnitude of energy, and methods of isolating and/or controlling it.
• When control methods change or new ones are implemented, employees must be retrained.
• And, as one of the Uretek Archer citations illustrates, audits are to be conducted at least annually.

LOTO Resources
Many manufacturers and suppliers offer a complete solution –- locks, tags, software, checklists, audit materials, and training. The OSHA Safety and Health Topics page about lockout/tagout, http://www.osha.gov/SLTC/controlhazardousenergy/index.html, is a good starting point for anyone seeking information about the standards; it points out that approximately 3 million workers routinely service equipment and thus face the greatest injury risk. When a worker is injured, the average time lost for recuperation is 24 days, according to OSHA.

It's an international problem. Britain's Health and Safety Executive, which updated its guidance document for sawmills last year, said sawmills in the United Kingdom have a major injury rate about two and half times higher than that of general manufacturing. "Machinery accidents remain one of the major causes of injury, with lock-out procedures for interrupting mechanised production processes still being a problem area. There is also an average of one fatality every year," HSE reported.

In November 2012, WorkSafe Victoria (http://www.worksafe.vic.gov.au/) announced an increased inspection program and launched an ad campaign with radio ads and billboards in Melbourne, Australia, that showed a worker with his hand caught in a meat grinding machine. An average of six workers per day are injured by moving machinery in Victoria, a southeastern state, and seven workers per month on average suffer an amputation in this way, the agency pointed out. Its campaign materials say $220 million has been spent on medical treatment, rehabilitation, and income support for almost 11,000 injured workers during the past five years. About 71 percent of those 11,000 work injuries occurred in manufacturing, construction, transport, warehousing, and storage industries.

"If a machine is used to mix, move, or stamp, then it can cut, crush, or amputate," said Lisa Sturzenegger, WorkSafe's Health and Safety Operations general manager. "They are the types of machines used across Victoria and are essential to many businesses, but the risks must be controlled. The risks are well known and the solutions are cheap, effective, and freely available."

Another good U.S. source for information about machine-specific lockout is the Michigan Occupational Safety and Health Administration. Its fact sheet on this topic (http://www.michigan.gov/documents/dleg/machine_specific_lockout_292562_7.pdf) notes a clearly stated machine-specific lockout procedure is essential and can be created in various ways, including color-coding to identify energy sources and lock locations, photographs with arrows and text identifying lockout points, or a combination of the these two methods.

This article originally appeared in the January 2013 issue of Occupational Health & Safety.