LOCKOUT TAGOUT REMOVING AMBIGUITY FROM CONTROL OF HAZARDOUS ENERGY PROGRAMS CONTROL OF HAZARDOUS ENERGY PROGRAMS

Outline  Personal Experience: Life is more complicated than you can imagine…  Review of OSHA Control of Hazardous Energy Program –Procedures –Training –Inspections  LO/TO Fatality Case Review

Life is more complicated than you can imagine  Children and puzzles,

Life is more complicated than you can imagine  Adults and more complex puzzles....

UTILIZING THE OSHA CONTROL OF HAZARDOUS ENERGY STANDARD REVIEW  Highlights –Applies to all conditions where unexpected energization could result in injury –Exceptions: minor servicing, workers effectively protected by alternative measures, power source under exclusive control of employee (cord and plug), etc - (c)(4)(i)

OSHA STANDARD  Specifies Requirement for Energy Control Program –Procedures –Employee Training –Inspection

ENERGY CONTROL PROGRAM Procedures  Identify, list, and specify energy isolation points for all energy sources for each piece of equipment that falls under the OSHA Standard –Electrical –Pneumatic  Steam –Spring/Gravity –Thermal –Hydraulic –Other

Procedures – Identify, List & Specify How?Who?

Procedures Cont’d  Specify Lockout Application (Pre-work) 1.Notify affected personnel 2.Properly shut down machine 3.Isolate all energy sources 4.Apply lockout devices, locks & tags 5.Verify total de-energization of all sources 1.Test by trying to activate 2.Return controls to off

Procedures Cont’d  Specify Lockout Removal Procedures (Post-work) 1.Ensure removal of all tools and items 2.Confirm safe location of all employees 3.Verify controls in neutral 4.Remove lockout devices and reenergize machine 5.Notify affected employees that servicing is complete

Procedure Example Example: Perfect Binder

Procedures Cont’d  Specify Testing Procedures: 1.Testing to be overseen by project leader 2.Leader will ensure all personnel are away from any unprotected parts of machine 3.Leader will oversee the removal of locks and tags 4.Leader will position self in a position to observe but away from the running machinery and away from any hazardous conditions 5.Leader will power and test part 6.Leader will oversee the reattachment of locks and tags to make adjustments or continue work

Procedures Cont’d Planning for events where no procedures have been specified (pg 1 of 2)

page 2 of 2 Procedures Cont’d

Energy Control Program Training  Who? –“Affected employee." One whose job requires him/her to operate or use a machine on which maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such maintenance is being performed. –"Authorized employee." A person who locks out or tags out machines in order to perform maintenance.

Training Continued *Critical that employees understand where they sit in these employee groups – this removes much of the ambiguity in the Lockout/Tagout Program

Training Continued When to LOTO The lockout/tagout standard contains specific criteria for the minor servicing exception. The three criteria determine if the minor servicing exception would apply to a particular activity. 1.The activity must take place during, and must be inherent to normal production operations 2.The activity must be 1.Routine: The activity must be a regular course of procedure and be in accordance with established practices. 2.Repetitive: The activity must be repeated as part of the production process or cycle. 3.Integral: The activity must be inherent to the production process. 3.If all of these apply, the employer must use alternative measures to provide effective protection from the hazardous energy.

Energy Control Program Annual Inspection  Periodic inspections of the energy control procedures are integral to ensure that the procedures and the requirements of the standard are being followed.  Annual Inspection Elements  Observe implementation of procedure by representative number of authorized  Conduct a procedure review/audit with all authorized employees  Inspection Details: 130 machines, 51 procedures are unique from one another – how many observations need to be performed?

Core Energy Control Program Summary  Establishing and improving upon procedures, training, and inspections of an energy control program leads to clear (and safe) sailing ahead. (Anon.)  Ambiguity is the devil’s volleyball. (Emo Phillips)

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