Best Practices

Review of proper lockout/tagout/blockout procedures


By Guest Contributor on 1/11/2016

OSHA’s standard for the control of hazardous energy -- 29 CFR Part 1910.147 -- exclusively addresses the practices and procedures that are necessary to disable machinery and equipment to prevent the release of hazardous energy while employees or contractors perform servicing or maintenance activities.

OSHA’s database shows that lack of proper lockout/tagout (LOTO) procedures in the general food industry resulted in 28 fatalities and 227 serious injuries between 2003 and 2013. It’s estimated that compliance to OSHA’s LOTO standard prevents 120 deaths and 50,000 injuries annually.

Depending upon the discretion of the USDA/FSIS inspector, LOTO of equipment and machinery is to be performed by the establishment prior to pre-operational inspection.

10 procedures to know

Energy control program (ECP) 1910.147(c)(1)

The employer shall establish a program of energy control procedures, employee training and periodic inspections to ensure that before any employee/contractor performs any servicing on a machine or equipment, where the unexpected energizing, start-up or release of stored energy could occur and cause injury, the machine/equipment is isolated from the energy source and rendered inoperative.

Energy hazards

  • Electricity
  • Hydraulic pressure
  • Hydraulic accumulation
  • Pneumatic
  • Gas
  • Steam
  • Thermal
  • Gravity
  • Kinetic spring tension
  • Fluids

Energy control procedures – 1910.147(c)(4)

These procedures shall specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy; including the means to enforce compliance.

Protective materials/hardware – 1910.147(c)(5)

LOTO devices shall be standardized (color, shape, size) and personalized to each person and used exclusively for LOTO. Lockout devices shall be substantial to prevent removal without excessive force. Tagout devices and their attachment must be substantial to prevent accidental removal of 50 pounds minimum unlocking strength, while warning of hazardous conditions.

Inspections - 1910.147(c)(6)

Employers shall conduct periodic inspection of their energy control procedure at least annually to ensure that the procedures and requirements of OSHA are being realized.

  • The periodic inspection shall be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected.
  • The periodic inspection shall be conducted to correct deviations/inadequacies identified.
  • Where lockout is used for energy control, the periodic inspection shall include a review between the inspector and each authorized employee, of that employee’s responsibilities under the energy control procedure being inspected.
  • Where tagout is used for energy control, the periodic inspection shall include a review between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure.
  • The employer shall certify inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person(s) performing the inspections.

Employee training – 1910.147(c)(7)

The employer shall provide training to ensure that the purpose and function of the ECP are understood by employees and that the knowledge/skills required for the safe application, usage and removal of the energy controls are employed by employees.

  • Each authorized employee receives training in the recognition of applicable hazardous energy sources, type and magnitude of the energy available in the workplace, and the methods/means necessary for energy isolation and control.
  • Each affected employee shall be instructed in the purpose and use of energy control procedure(s).
  • All other employees whose work operations are or may be in an area control procedures are utilized, shall be instructed about the procedure, and the prohibition relating to attempts to restart/reenergize machines or equipment which are locked or tagged out.

When tagout systems are used, employees shall be trained in the following limitation of tags:

  • Tags are essentially warning devices affixed to energy isolating devices and do not provide the physical restraint on those devices that’s provided by a lock.
  • When a tag is attached to an energy isolating means, it’s not to be removed without authorization of the authorized person responsible for it: It’s never to be ignored, bypassed nor defeated.
  • Tags must legible/understandable by all authorized/affected employees and all other employees whose work operations may be in the area for effectiveness.
  • Tags and their means of attachment must be made of material that withstands the environmental conditions encountered at the workplace.
  • Tags must be securely attached to energy isolating device(s) so they cannot be inadvertently/accidentally detached during use.

Retraining – 1910.147(c)(7)(iii)

Retraining shall be provided for all authorized and effected employees whenever there is a change in job assignments, change in machines, equipment or processes that present a new hazard, and when there is a change in the energy control procedures. The employer shall certify that employee training has been accomplished and is kept current. The certification shall contain each employee’s name and dates of training.

Application of control – 1910.147(d) and Release – 1910.147(e)

Before an authorized or affected employee shuts off a machine or equipment, the authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of energy to be controlled and the method/means to control energy.

  • The machine/equipment shall be turned off or shut down using the procedures established for the machine/equipment.
  • All energy isolating devices needed to control the energy shall be physically located in such a manner as to isolate the machine/equipment from all energy sources.
  • Lockout or tagout devices shall be affixed to each energy-isolating device by authorized employees.
  • Tagout devices shall be affixed that will clearly indicate that operation or movement of energy isolating devices from the safe or off position is prohibited.
  • Where tagout devices are used with energy isolating devices, the tag attachment shall be fastened at the same point that the lock would have been attached.
  • If a tag cannot be affixed directly to the isolating device, the tag shall be located as closely as possible to the device so it is in a position “obvious” to anyone.
  • Following the application of a lockout or tagout, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained and rendered safe.
  • If there is possibility of re-accumulation of hazardous energy, verification of isolation shall be continued until servicing is completed or the accumulation no longer exists.
  • Prior to starting work that’s been locked or tagged out, the authorized employee shall verify that isolation and de-energization has been accomplished.

Before LOTO devices are removed and energy is restored to the machine or equipment, procedures shall be followed by the authorized employee(s):

  • Work area is inspected to ensure nonessential items have been removed and the components are operationally intact.
  • Work area is checked to ensure all employees are safely positioned.
  • After the LOTO devices are removed and before a machine/equipment is started, affected employee(s) shall be notified that the LOTO device(s) have been removed.
  • Each LOTO device shall be removed from each energy-isolating device by the employee whole applied the device. (Exception: when the authorized employee who applied the LOTO device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures/training has been developed and is included within the employer’s program. This can only be done when the authorized employee is not at the facility; reasonable efforts were made to contact the person; and the authorized employee is informed when resuming work at the facility.)

Outside contractors – 1910.147(f)(2)

When outside contractors (including USDA inspectors) are engaged in activities covered by the scope of this standard, the on-site employer and contractor shall inform each other of their LOTO procedures. The on-site employer shall ensure that their employees understand and comply fully with the restrictions/prohibitions of the contractors ECP.

Group LOTO 1910.147(f)(3)

When servicing/maintenance is performed by a group, a procedure which affords the employees a level of protection equivalent to that provided by the implementation of a personal LOTO device shall be utilized.

Group LOTO devices shall be used in accordance with the procedures required by section 1910.147(c)(4) but isn’t limited to the following:

  • Primary responsibility is vested in an authorized employee for a set number of employees working under the protection of a group lockout or tagout device.
  • Provisions for the authorized employee to ascertain the exposure status of individual group members with regard to the lockout or tagout of the machine or equipment.
  • When more than one department is involved, overall job-associated lockout or tagout responsibilities are assigned to an authorized employee designated to coordinate affected work forces and ensure continuity; and each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox or comparable mechanism when one begins work and remove those devices when one stops working on the machine or equipment. 

Shift or personnel changes – 1910.147(f)(4)

Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of lockout/tagout protection, including provision for the orderly transfer of lockout/tagout device protection between ingoing and outgoing employees to minimize exposure to hazards from the unexpected energization or start-up of the machine/equipment – including the release of stored energy.

 

-- Steve Sayer owns S&R Consulting, LLC

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