What you need to know about LOTO.
By Joan Shirikian
Lockout/Tagout, or LOTO, is not a state lottery. It is a program that has no room for chance. If your LOTO program is being run as a lottery or a game of chance, it needs to be reviewed and changed.
LOTO is a critical component of your safety program. It refers to the main mechanism used by the Energy Control Program to ensure the safety of workers performing service and/or maintenance on machines or equipment that may expose them to an unexpected energization, startup or release of hazardous energy.
Under the standard 29 CFR 1910.147, the following definitions apply.
Servicing and/or maintenance
Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, maintaining and/or servicing machines or equipment, including lubrication, cleaning or unjamming of machines or equipment, and making adjustments or tool changes where employees could be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.
Unexpected also covers situations in which the servicing and/or maintenance is performed during ongoing normal production operations if:
- An employee is required to remove or bypass machine guards or other safety devices; or
- An employee is required to place any part of his or her body into a point of operation or into an area on a machine or piece of equipment where work is performed, or into the danger zone associated with the machine’s operation.
Lockout is the placement of a lockout device on an energy-isolating device, in accordance with an established procedure, ensuring that the energy-isolating device and the equipment being controlled cannot be operated until the lockout device is removed.
Any device that uses positive means, such as a lock, blank flanges and bolted slip blinds, to hold an energy-isolating device in a safe position, thereby preventing the energizing of machinery or equipment.
Tagout is the placement of a tagout device on an energy-isolating device, in accordance with an established procedure, to indicate that the energy-isolating device and the equipment being controlled may not be operated until the tagout device is removed.
Energy sources are not just electrical sources. Energy sources include electrical, mechanical, hydraulic, pneumatic, chemical, thermal, solar or any other energy producing medium. Disconnecting the electrical power does not begin to ensure that a piece of equipment or parts of the equipment won’t start. Other applicable definitions can be found in 29 CFR 1910.147 (b).
Energy Control Program
The Energy Control Program consists of three core components: energy control procedures, employee training and periodic inspections.
Energy control procedures require a very systematic approach. Positive actions are required to ensure that before servicing or maintenance commences, every type of energy has been dissipated, everything is in a neutral position and all energy sources are locked out. Positive lockout should be used to prevent equipment activation until each individual performing the service has removed his/her positive controls from each energy source.
No matter what is being locked out, certain steps are required to develop sound procedures.
- Identify all energy sources.
- Track schematics on how and what parts of the equipment each energy source controls.
- Identify means to Lock Out each energy source.
- Dissipate all stored energy ensuring every aspect of the equipment achieves neutral position.
- Check and test all switches making sure nothing starts or activates when any control is placed in the on position.
- During implementation of the procedures it is essential that all affected employees are notified at the start and finish of the lockout.
It is a common practice to bleed hydraulic or pneumatic lines once the source has been locked out to ensure no stored energy will be released. Likewise it may be necessary to disconnect parts of the electrical system, such as solenoids, to ensure all electrical energy has been dissipated after the main electrical source has been locked out.
Regardless of the type of energy source, one must always know what position various parts of the system are in when the source is removed. Think of a spring that controls a gate. The energy source is identified, deactivated and locked out. However, if this leaves the spring compressed and the gate open, as maintenance work progresses the spring may be compromised and release (it has stored energy in the compressed position), causing the gate to close. This could injure anyone near the gate.
Employee training is the next component. There are two levels of training. One is for employees that could be affected by the lockout of a piece of equipment. These folks won’t be performing the actual lockout, but they must be able to recognize that a lockout is in place and know what to do and not do during the lockout. They must never try to remove any locks or tags. They also need to understand that they should never try to start a piece of equipment involved in a lockout.
The second level of training is for employees who will be performing the lockout/tagout. They need to understand the procedure and be comfortable that it does lock out all energy.
Periodic inspections is the third component, a two-fold process. There must be a physical inspection of each lockout procedure to ensure that it does in fact lock out all energy sources. There also needs to be a review of those employees authorized to perform lockout to ensure they have been adequately trained for the task.
Specific expectations and requirements for each of these components can be found in CFR 1910.147. It is essential that every piece of equipment that employees maintain or service has a specific detailed procedure.
In many precast plants, LOTO is the process used to control hazards for the various parts of the batch plant. This is necessary so equipment can be safely serviced. (Note: depending on the environment, confined space procedures may be required.)
Consider all equipment
Precast operations have a variety of equipment that will require specific LOTO procedures for each to ensure safe maintenance and servicing: rebar benders, wire cutters, mixers, conveyors, automated overhead doors, cranes, mixer trucks, buckets, bullets, monorails, etc. Additionally, even if a piece of equipment isn’t being worked on, it may require a lockout to ensure the safety of employees working on other equipment or performing other tasks. Changing a light bulb in an overhead plant fixture often requires the lockout of one or more cranes. This is the only way to ensure the nonoperation of a crane, which could otherwise knock out the ladder or lift that is being used to access the overhead light.
When equipment is being serviced, maintained or unjammed, it takes only a split second for someone to be injured if a proper lockout procedure hasn’t been developed or isn’t used.
Common pitfalls or areas often overlooked in complying with 29 CFR 1910.147 include:
- Providing unique locks for use with LOTO and ensuring they are never used for any other purpose
- Ensuring that each lock used has the individual employee identified
- Developing procedures to cover situations involving shift changes
- Developing procedures to use when someone’s shift is over and he or she forgot to remove his or her lock
- Identifying methods to use for multiple locks when more then one individual is involved
- Ensuring that lockout locks have only one key
The steps are specific
Develop a written Energy Control Program and keep it with your safety manual. Survey the plant and develop equipment-specific procedures for anything that can be energized. Train all employees as either “affected” or “authorized” employees regarding LOTO. Make sure all procedures are properly implemented and consistently followed. There is no room for mistakes when servicing and maintaining the equipment found in a precast operation.
Use this General Lockout/Tagout Procedure Checklist, taken from 29 CFR 1910.147.
Prepare for equipment shutdown
- Notify all affected employees
- Know what type of energy is involved
- Know how energy is controlled
- Shut down Equipment
- Turn off by normal means
- Turn off energy feed switches or valves
- Isolate all energy: valves, circuit breakers, switch boxes, plugs, hydraulic and pneumatic lines, etc.
- Insert safety blocks
- Attach lock and tag
- Double check energy sources
- Test activate all switches and then deactivate them
- Recheck that all switches are in “Off” position and locked with a lock from everyone involved
- Control stored energy
- Check for stored energy and dissipate
- Replace all guards
- Remove all tools
- Notify all affected employees of startup
- Unlock (each person must unlock his or her own lock)
- Start equipment
Joan Shirikian is the Northeast Regional Safety Manager for Oldcastle Precast Inc. and a member of NPCA’s Safety, Health & Environmental Committee.