OSHA “Hot Topics” Lockout/Tagout Review

DIRECTIVE NUMBER: CPL EFFECTIVE DATE: 2/11/08 SUBJECT: The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures

Review Scope: this standard covers the servicing and maintenance of machines and equipment in which the “unexpected” energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. The standard establishes minimum performance requirements for the control of such hazardous energy.

Review Application: This standard applies to the control of energy during servicing and/or maintenance of machines and equipment. Normal production operations are not covered by this standard (See Subpart O). Servicing and/or maintenance which takes place during normal production operations is covered by this standard only if: –An employee is required to remove or bypass a guard or other safety device, or –An employee is require to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed or where an associated danger zone exists during a machine operating cycle.

Review NOTE: Exception; minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard, if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O). Standard does not apply to: Work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start up is controlled by the unplugging of the equipment and by the plug being under the exclusive control of the employee performing the servicing or maintenance. Hot tap operations involving transmission and distribution systems (gas, steam, petroleum, water)…………

Review Purpose: this section requires employers to establish a program and utilize procedures for affixing appropriate lockout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up, or release of stored energy in order to prevent injury to employees.

Definitional “Tidbits” Energy Isolating Device: A mechanical device that physically prevents the transmission or release of energy, including manually operated circuit breakers, disconnect switches, line valves, blocks…… Push buttons, selector switches, and other control circuit type devices (i.e. interlocks, light curtains) are not energy isolating devices. An electrical switch may be an energy-isolating device if it physically prevents the transmission of electrical energy. Additionally, the mechanical isolating device must also simultaneously open all ungrounded conductors of the supply circuit and no pole can be operated independently.

Tidbits Normal production operations: the utilization of a machine or equipment to perform its intended production function. Servicing and/or maintenance: activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. Including, lubrication, cleaning or unjamming, making adjustments or tool changes, where the employee may be exposed to unexpected energization, startup, or release of hazardous energy.

Program Energy control “specific” procedures –Shall be developed, documented, and utilized Employee training –Purpose and function of program understood –Knowledge and skills for safe operation acquired –Certify Periodic inspections –Annual inspection of energy control procedures –Performed by authorized employee other than the one(s) utilizing the procedure being inspected….therefore, at least 2 authorized employees required –Certify Machine, date, employee(s), inspector

Most Frequently Cited Serious Violations in General Industry FY 2007 Machine Guards - General Eye & Body Flushing Facilities Point of Operation Open-Sided Floors Conductors Entering Cabinets/Boxes/Fittings Protected from Abrasion Lockout/Tagout - Program Grinders-Tongue Guards Hazard Communication – Information & Training Note: There were also 1277 Section 5(a)(1) General Duty Clause violations cited for all inspections during this period. Lockout/Tagout - Procedures Hazard Communication – Written Program

Subpart J - General Environmental Controls ( ) Lockout/Tagout - Program Lockout/Tagout - Training Lockout/Tagout - Procedures Lockout/Tagout - Content of energy control procedures Standard: Lockout/Tagout procedure - Periodic inspection

Energy Control Procedures Cornerstone of the LOTO standard because they provide employees the guidance necessary to effectively and safely control hazardous energy when they service or maintain machinery or equipment. The requirement to develop procedures is performance-oriented, but ultimately the procedures must explain what employees must know and state what steps employees must take to effectively and safely control hazardous energy during the servicing/maintenance activities. Procedures must clearly and specifically outline the steps to be followed, techniques to be used, and measures to be applied by the employer to ensure that the procedure is used (c)(4)(ii) gives details on the minimum elements for the procedure…….the amount of detail will depend upon the complexity of the machine/equipment and the information necessary to safely control the hazardous energy.

Energy Control Procedures Typical Minimal Lockout Procedure Appendix A (handout) For the purposes of procedure grouping, machines and equipment may be grouped together as one procedure if they all are listed or identified in the scope of the energy control procedure and if they all have the same or similar: –Procedural steps for shutting down, isolating, blocking, securing, and dissipating stored energy in machines or equipment; –Procedural steps for the placement, removal, and transfer of the lockout or tagout devices and the responsibility for them, and –Requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other control measures.

Procedure Grouping - Examples Multiple power presses with similar design characteristics and energy sources = group die-setting activities into a single procedure. Many woodworking machines (e.g. tables saws, radial arm saws, planers, routers, grinders) in a shop are similar for purposes of the energy control procedure requirements because they all use relatively the same or similar types of energy (e.g., 120 VAC and 240 VAC, nominal electric disconnect switches), have the same or similar controls for isolating the machines from the energy source, and use the same sequential procedural steps to protect employees from the mechanical hazards (e.g., shut off the machine; open the electric disconnect adjacent to the machine; apply a personal LO device; allow the blades or other machine components to stop before removing the guards; verify that the machine is isolated and cannot unexpectedly start up).

Procedure Grouping - NOTE OSHA recognizes that some employers choose to develop “machine- specific” energy control procedures for individual machines or pieces of equipment because this approach provides an optimum level of detail, enhancing overall employee safety during servicing operations. In order not to discourage this practice, employers who develop energy control procedures for individual machines still may group same or similar individual machine/equipment procedures for periodic inspection purposes.

(c)(4)(i) documentation exception This exception is intended to apply to situations in which the LOTO process can take place without detailed interactions of energy sources, machines/equipment, and employees. If the scenario meets each of the following elements, the procedure would need to be developed and utilized but not documented: –There is a single source of hazardous energy that can be easily identified and isolated, and there is no potential for stored or residual energy in the machine; –The isolation and locking out of that single energy source will totally de-energize and deactivate the machine; –A full lockout of the energy source is achieved by a single lockout device, which is under the exclusive control of the authorized employee performing the servicing, and –The servicing, while the machine is locked out, cannot expose the other employees to hazards. NOTE: there are eight conditions that must be met in order to take advantage of this exception. See (c)(4)(i).

Periodic Inspections Due to the significant risks associated with inadequate energy control procedures and the failure to properly implement effective energy control procedures, section (c)(6)(i) requires that periodic inspections be performed at least annually (based on twelve-month intervals) to verify that the procedures are adequate AND being properly applied. –NOTE: Energy control procedures used less frequently than once a year (based on a 12-month interval) need be inspected only when used. –NOTE: Energy control procedures that are not required to be documented, still need to be inspected and reviewed to ensure adequacy and proper utilization. –Must contain two components: 1) an inspection of each energy control procedure, and 2) a review of each employee’s responsibilities under the energy control procedure being inspected. –Inspector must be an authorized employee other than the one(s) utilizing the energy control procedure being inspected.

Periodic Inspections A review of the employee’s responsibilities under the procedure is the second periodic inspection component. At a minimum, these inspections must include a demonstration of the procedures and must be performed while the authorized employees perform servicing and/or maintenance activities on machines or equipment……………and the inspector must talk with employees implementing the procedure to determine that all the requirements of the LOTO standard are understood and being followed by employees. A grouping of individual procedures, meeting the criteria discussed previously, would be considered one procedure for periodic inspection purposes………then inspect a representative number of employees implementing one procedure within each group. These representative procedure inspections must reasonably reflect plant servicing and/or maintenance operations and practices.