Staying in Control

Paradoxically, given the number and gravity of annual violations, the standard is easy to understand and apply.

MANY industries must maintain rigid adherence to mandatory safe practices in machine maintenance and operations. For workers in laboratories, paper and wood products, chemicals, recycling operations, automotive assembly and repair, and many other settings, successful lockout/tagout is essential to safety and survival.

OSHA reiterated in 2002 that while its standard (29 CFR 1910.147, The Control of Hazardous Energy [Lockout/Tagout]) doesn't cover power generation, transmission, and distribution; agriculture; construction; maritime; or oil and gas well drilling and servicing, other standards concerning control of hazardous energy may apply in those industries. 1910.147 also does not apply in general industry when exposure to hazardous energy is completely controlled simply by unplugging the equipment and where the maintenance employee has exclusive control of the plug.

Paradoxically, given the number and gravity of annual violations, the standard is easy to understand and apply. Among manufacturing industries, 1910.147 was the most-cited OSHA standard in October 2002 through September 2003, with 291 inspections producing 555 citations that totaled $650,392 in penalties, by the agency's latest tally.

Workers doing service or maintenance work during normal production operations must follow LOTO procedures if they do any of these three things:
* Remove or bypass machine guards or other safety devices,
* Place any part of their bodies in or near a machine's point of operation, or
* Place any part of their bodies in a danger zone associated with machine operations.

The mandate applying to covered employers is equally straightforward. Their energy control programs must include:
* Procedures for removing the energy supply from machines and placing appropriate lockout or tagout tools on the energy-isolating devices (and also, where appropriate, addressing stored or potentially reaccumulated energy),
* Training for employees, including on the safe application, use, and removal of energy controls, and
* Inspection at least annually of the procedures to ensure they are followed and remain effective at preventing employee exposure.

At a minimum, an employer's procedures must contain: a statement on how to use the procedures; specific steps to shut down, isolate, block, and secure machines; specific steps for safe placement and removal of locks and tags and names of those responsible for the locks and tags; and specific requirements for testing machines to determine and verify the effectiveness of all energy-control measures. The employer's training (certified with each affected employee's name and the date when it took place) must be initial training before maintenance/servicing begins and also retraining whenever job assignments or energy-control procedures change, or machinery or processes present a new hazard.

Notifying affected employees is critical at two points in the process--before the lockout procedure begins and also before lock/tag removal and restart. Equally critical are the roles those workers play, both individually and collectively. A designated employee must disconnect machinery and lock it out.

Only the person who applied the locks or tags is authorized to remove them (although 1910.147(e)(3) explains how another person may do so under the employer's direction, if the original employee cannot remove the device). All employees must be trained to respect locks and tags fundamentally, in all circumstances, because the life-threatening risks of accidental restart have been explained to them.

Lockout and tagout devices are not equal in OSHA's eyes. If employers use tagout tools on machinery capable of being locked out, "they must adopt additional measures to provide the same level of employee protection that lockout devices would provide," the agency says.

A good practice is to label every energy-isolating device to indicate its function, with the label identifying the equipment is supplies and also the energy type and magnitude. Many employers also prepare written checklists for their equipment addressing equipment access, LOTO clearance, release, and restart. Following company lockout/tagout procedures is the best way to ensure the safe control of energy.

Some situations call for a multiple, or group, LOTO procedure. Everyone working on the machinery or piece of equipment must place his lock or tag on the energy-isolating device. (The device may not accept multiple locks or tags, so a hasp can be used.) Each worker later removes his own lock or tag.

Tips for Effective Training
* Graphic examples of machine-related injuries can be effective motivators. You might mention this summer's $203,100 fine by Washington state's Department of Labor and Industries after it investigated the death of a worker at a paper mill. Telling them the worker died in a paper cutter when someone else inadvertently started it, according to L&I, may be all you need to say to get your point across.

* Train more thoroughly and more frequently than OSHA demands. "Periodic" training must be annual, at least, but it should be much more frequent to make sure lockout/tagout is followed whenever it is needed, without exceptions.

* Document each and every infraction of your LOTO policy. Supervisors cannot afford to be lenient here. Cut no slack to anyone. The risks and the penalties for failure are simply too great to take chances.

* Communicate fully with contractors and other outside personnel who are working on site and may be exposed. The host employer and the outside employer must inform each other of their lockout/tagout procedures and ensure their employees comply with the other firm's procedures.

* Be especially vigilant when shifts change. Incidents often occur soon after a shift change because of poor communication. Those going off shift should meet incoming personnel at the lockout/tagout device, with the arriving worker placing his lock or tag before the departing employee removes his. Exiting employees should alert arriving workers about any problem or concern related to machine maintenance that has arisen during the shift.

Tough, no-nonsense LOTO policies will serve you well.

This article originally appeared in the September 2004 issue of Occupational Health & Safety.

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