Monday - Lockout/Tagout
This week’s discussion is on compliance with OSHA Lockout/Tagout (LOTO) requirements. LOTO is the process to control hazardous energy during the servicing and maintenance of machines and equipment.
Hazardous energy sources include:
LOTO procedures protect employees against an unexpected start up or release of stored hazardous energy. Employees servicing or maintaining machines or equipment may be seriously injured or killed if hazardous energy is not controlled.
Injuries involving hazardous energy can include:
“During 1982–2006, NIOSH investigated 185 fatalities related to installation, maintenance, service, or repair tasks on or near machines, equipment, processes, or systems. Failure to completely de-energize, block, and/ or dissipate the energy source was a factor in 142 (77%) of the incidents; failure to lockout and tagout energy control devices and isolation points after de-energization was a factor in 31 (17%)” (CDC.gov). According to EHS Safety News America, compliance with the lockout/tagout standard (29 CFR 1910.147) prevents an estimated 120 fatalities and 50,000 injuries each year. Following Lockout Tagout procedures is a matter of life and death!
Tuesday – Lockout/Tagout - Seven Steps for Shutdown
LOTO is more than just putting a lock on the main electrical disconnect to a machine, in fact, there are 7 very important steps you must do when putting LOTO in place:
- NOTIFY – Notify all affected employees that you are going to be conducting a LOTO.
- PREPARE – Before you begin, ensure you know all types of energy involved, hazards presented, and how to control the energy.
- SHUTDOWN – Turn off machine or equipment.
- ISOLATE - Isolate machine or equipment from its energy source(s). (For example, turn off main circuit breaker.)
- LOCKOUT – Apply your lock. Be sure that it holds the isolating device in the “off” or “safe” position.
- RELEASE - Release stored energy. Relieve, disconnect, restrain, block, or otherwise ensure, that all energy sources – electrical, mechanical, hydraulic, compressed, etc. are de-energized.
- VERIFY/TRY – Try the on-off switch or other controls to be sure the machine won’t start. Return the switch to the “off” position.
Now LOTO is complete!
Wednesday – Applying Lockout/Tagout
LOTO procedures apply in the following circumstances:
- An employee is required to remove or bypass a guard or other safety device; or
- An employee is required 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 (point of operation) or where an associated danger zone exists during a machine operating cycle.
Note Exception to paragraph (a)(2)(ii): 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
Thursday – Lesson Learned
*** A facility was recently cited by OSHA because LOTO was not properly used when changing out a blade on a drum cutter, this was done 1-2 times per shift. The facility considered this activity a minor service and exempt from LOTO requirements. OSHA interprets the ‘repetitive’ portion of this standard to mean approximately 4 times per hour. Further, the use of tools, unfastening bolts and/or removing guards to change out tooling is not considered minor servicing during production and requires LOTO, even if the guards are interlocked. It is CRITICAL to understand this requirement and are in full compliance. ***
The citation mentioned above highlights areas of opportunity for us to pay attention to at each of our sites. We need to fully evaluate areas where we might be operating under minor servicing but should be using full LOTO. For example: blade change outs on band saws or circular saws, grinding wheels, drill bits, etc. would all fall under LOTO regulations and need to be fully de-energized prior to minor servicing.
Please take the time to review all of the servicing requirements on machinery and equipment in your areas and verify that each area is following LOTO procedures when they are applicable. If there are concerns about when LOTO applies, please let your supervisor know so they can follow-up accordingly. Report issues, questions, and/or concerns to your supervisor immediately. Annual LOTO inspections are to be performed across the campus and it is a great time to go through the entire process to ensure it is covering all required bases. If training or other support is needed, please notify your EHS personnel.
Tags: safety topics , osha compliance , osha training basics ,
Friday - Find It First Friday
Take a few minutes right now and survey your areas for Safety Opportunities. If we can find and fix these first, then we put up roadblocks to a potential injury. Remember, when reporting a Safety Opportunity, include suggested corrective actions!