Mark Scott, ESP Manager RSC Meeting May 9 th, 2013 ES&H Manual Lockout/Tagout Program 2013 Draft Revision.

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Presentation transcript:

Mark Scott, ESP Manager RSC Meeting May 9 th, 2013 ES&H Manual Lockout/Tagout Program 2013 Draft Revision

Objectives Improve the quality of written LOTO Procedures: Stricter rules for scope of work, isolation checklists, and approvals Improve execution of written LOTO Procedures: Layered roles and responsibilities Heavy emphasis on the LOTO person in charge Adjust the LOTO training requirements to match real Lab needs: Personnel with limited LOTO needs receive less training Personnel with extensive LOTO needs receive more training Net neutral training impact to the Lab Primary 2

Objectives Reformat the existing PUB-3000 Chapter 18 to meet the new RPM standard style guide for the ES&H Manual General upgrade to improve overall clarity Incorporate a number of specific corrective actions related to LOTO incidents over the last two years Capture the 2012 Subcontractor LOTO Permit process improvements Align terminology to regulatory standards Secondary 3

Working Group Bob Mueller Tim Kuneli Jim Murphy Tom Caronna Doug Burkhardt Seiji Nakagawa Peter Marietta Mike Johnson Prabir Roy Mark Scott Richard DeBusk EHSSScience Eng.Fac. Lab-wide representation 4

Timeline Draft Development 1/1/13 – 6/1/13 Rough Draft SME Smooth Draft Working group input Final Draft User input Implementation Planning 6/1/13 – 9/30/13 RPM planning JHA transition Training development Hardware procurement (tags) Budget impacts Rollout 10/1/13 – 9/30/14 Change JHA’s Launch new training modules Full SmartSheet GANTT chart available for viewingSmartSheet GANTT chart 5

Principles of LOTO Main Components 6 Lockout ProgramDeenergization Isolation of all energy sources Dissipation of stored energy Verification of deenergization Control Written Lockout Procedure Assigned Person In Charge All personnel are personally locked out for duration New focus area

Responsible Individual Person in charge, is accountable for the safe execution of the LOTO Authorized Person Performs work under a LOTO Establishes Simple and some Complex LOTO’s Affected Person Anyone impacted by the LOTO but not performing any work under the LOTO Three Training Levels New training level: Responsible Individual (RI) 7

Energized Work vs. LOTO Energized Testing is OK: the equipment cannot be shut down for the work being performed (testing, alignment, calibration, troubleshooting, etc…) All other work must be performed under LOTO Interlock protection is NOT SUFFICIENT for deenergized work LOTO Machine Guarding Lasers High Voltage RoboticsRF 8

Radiological Exemption Radiological hazards that are controlled by 10 CFR 835 are exempt from 10 CFR 851 Includes ionizing radiation, follow the Radiation Protection Program requirements instead Work area must be covered by the Credited Control Radiation Safety System interlocks For ionizing radiation only! 9 Lasers and RF are not exempt from LOTO controls Working in a hazardous beamline is subject to the requirements of the LOTO Program. Energized work is subject to program authorization and controls Shutdown repair work is subject to LOTO: interlocks are not sufficient EXEMPT NOT EXEMPT

Improper use of LOTO lock Locking an interlock to prevent hutch door from closing, to prevent beamline turning on, even though the beam is controlled by RPP… 10

Missing LOTO High voltage and RF hazards not controlled by LOTO, only by interlocks 11

Setting Thresholds The various safety programs must communicate the hazard thresholds established by recognized standards Example: Electrical: ≥50 VAC and ≥ 5 mA Lasers: Class 3b and 4 RF: ? Machines: whenever guard is removed Robotics: ? The various safety programs must also communicate when LOTO is required according to the LBNL LOTO Program Specify what type of activities can be performed energized Specify what type of activities must be performed under LOTO 12

Next Steps Funnel comments, questions and concerns to me I prefer handwritten mark-ups on printed paper, but I’ll take any format that is constructive All edits to the draft will be reviewed and approved by the Working Group You are welcome to participate in the Implementation Planning: Training review JHA revision development Web resources development There’s plenty of time to provide input 13

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