By Evan Gurley
The fifth most cited Occupational Safety and Health Administration violation in 2015 – one which is consistently part of OSHA’s top 10 cited violations for the past 5 years – is lockout/tagout being overlooked. If this sounds like déjá vu, it’s because we’ve reported it before. It bears repeating, though, because forgetting to lockout and tagout can cause more than citations, fines and injuries – it can cost a worker’s life. Strict enforcement of LOTO rules should always be maintained.
LOTO is a safety procedure critical for the service and maintenance of machinery or electrical systems in cases where employees could be injured by the unexpected startup of the equipment. It applies to all energy sources, including mechanical, hydraulic, pneumatic, chemical, thermal and gravity. An effective LOTO program protects workers by ensuring that machines and circuits are properly shut off and not turned on again until the work is completed.
Historically, 3/4 of LOTO violations are related to three sections of the standard. At the top of the list is Section (c)(4), which requires procedures be “developed, documented and utilized” for controlling potentially hazardous energy.
The biggest challenge for precasters seems to be identifying all the potential energy sources. Before OSHA issued the standard, many precasters may have thought turning off the electricity was enough to protect workers during servicing. However, there’s usually more than one energy source on equipment.
“OSHA requires written procedures for each piece of equipment you use and operate at your plant,” said Tom Engelman, president of Bethlehem Precast in Bethlehem, Pa. “Many employers may not realize that. And when you have the amount of equipment that typical precasters do, documenting detailed procedures for each piece of equipment can be time consuming. It’s not difficult, just time consuming.”
The second most violated part of the standard is Section (c)(1), which states an energy control program must consist of written procedures, training and periodic audits. Precasters can receive citations if they have no program at all or have major deficiencies. Violations might include complete lack of written control procedures or failure to audit the program.
“Constant refreshing and review of LOTO procedures and hazards is vital,” said Dan Wagner, president of Milan Vault in Milan, Mich. “Repetition is key.”
The third most violated part of the standard is Section (c)(7), which outlines training and communication elements. OSHA requires not only that employers teach workers about LOTO procedures and hazards, but also that employees have the knowledge and skills necessary to comply. The training stage is where LOTO programs can break down. A company may have a solid training program where the necessary safety information is relayed from the in-plant safety inspector to the floor supervisor, but it may stop there as the supervisor may already be overloaded with production-related tasks.
Other times, precasters may train employees effectively but forget to keep records. Documentation of training performed is required and it may even be beneficial to issue a certification for that particular training exercise.
On top of these requirements, some precasters may train their authorized workers, but not all employees at their plant. Or they may provide the appropriate classroom training, but not monitor and audit the employees to ensure procedures are correctly implemented and enforced. OSHA requires employers to check and document that workers are following the correct procedures at least once per year. And while these annual audits may be adequate for documentation purposes, employers should perform regular spot checks.
Employee classifications and requirements
Authorized employees must understand:
- Hazardous energy sources.
- The type and magnitude of the hazardous energy sources in the workplace.
- Energy-control procedures, including the methods and means to isolate and control those energy sources.
Affected employees must recognize:
- When the energy-control procedure is being used.
- The purpose of the procedure.
- The importance of not tampering with lockout or tagout devices and not starting or using equipment that has been locked or tagged out.
Other employees must receive training:
- Regarding the energy-control procedure and the prohibition against removing a LOTO device and attempting to restart, reenergize or operate the machinery.
- Regarding the limitations of tags if tagout devices are used.
According to OSHA, energy sources including electrical, mechanical, hydraulic, pneumatic, chemical, thermal or others in machines and equipment can be hazardous to workers. During the servicing and maintenance of machines and equipment, the unexpected startup or release of stored energy can result in serious injury or death.
The National Institute for Occupational Safety and Health investigated 185 fatalities over nearly 25 years that 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 77% of the incidents and failure to lockout and tagout energy-control devices and isolation points after de-energization was a factor in 17%. Failure to control hazardous energy accounts for roughly 10% of serious accidents in many industries. Workers injured in non-fatal accidents from exposure to hazardous energy lose an average of 24 workdays for recuperation.
Controlling hazardous energy sources
The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations, Part 1910.147, addresses the practices and procedures necessary to disable machinery and/or equipment, thereby preventing the release of hazardous energy while employees perform servicing and maintenance activities.
In addition, 29 CFR 1910.333 sets forth requirements to protect employees working on electrical circuits and equipment. This section requires workers to use safe work practices including LOTO procedures. These provisions apply when employees are exposed to electrical hazards while working on, near, or with conductors or systems that use electric energy.
The LOTO standard establishes the employer’s responsibility to protect workers from hazardous energy. OSHA states employers are also required to train each worker to ensure they know, understand and follow the applicable provisions of the hazardous energy control procedures. Training must cover at least three areas: aspects of the employer’s energy control program, elements of the energy control procedure relevant to the employee’s duties or assignment, and the various requirements of the OSHA standards related to LOTO. The standard also states:
- All employees who work in an area where energy control procedure(s) are used need to be instructed in the purpose and use of the energy control procedure(s), especially when it is unsafe to restart or reenergize locked or tagged out machines or other equipment.
- All employees who are authorized to lockout machines or equipment and perform the service and maintenance operations need to be trained in recognition of applicable hazardous energy sources in the workplace, the type and magnitude of energy found in the workplace, and the means and methods of isolating and/or controlling the energy.
- All employees must be retrained to maintain proficiency or introduce new or changed control methods.
What employers must do to protect employees
OSHA standard 1910.147 establishes requirements that employers must follow when employees are exposed to hazardous energy while servicing and maintaining equipment and machinery. Some of the most critical requirements from this standard include:
- Developing, implementing and enforcing an energy control program and procedures.
- Using lockout devices for equipment that can be locked out. Tagout devices may be used in lieu of lockout devices only if the tagout program provides employee protection equivalent to that provided through a lockout program.
- Ensuring new or overhauled equipment is capable of being locked out.
- Developing, implementing and enforcing an effective tagout program if machines or equipment are not capable of being locked out.
- Using only LOTO devices authorized for the particular equipment or machinery and ensuring they are durable, standardized and substantial.
- Ensuring the LOTO devices identify the individual users.
- Establishing a policy that permits only the employee who applied a LOTO device to remove it.
- Inspecting energy-control procedures at least annually.
- Providing effective training as mandated for all employees covered by the standard.
Engelman and Wagner offer additional insight for precasters when addressing in-plant LOTO procedures. Wagner said Milan Vault contacted a local energy provider for additional training. He also suggests precasters train every employee on why LOTO is important to follow for each piece of equipment.
“Repetition and constant refreshing is key when it comes to LOTO training,” Wagner said.
Engelman concurred, adding identifying and understanding all of the potential energy sources is crucial.
“We teach our employees the difference between stored and powered energy sources,” he said. “Stored energy is less obvious and requires additional training and refreshing.”
Having energy-control procedures is just the first step in ensuring your company is compliant with OSHA’s regulations regarding LOTO enforcement – constantly ensuring your energy-control procedures are being followed is the next logical step. Making sure they are understood and enforced is crucial for the safety of every employee.
Evan Gurley is a technical services engineer with NPCA.