How to Avoid Putting Your Lockout/Tagout Program at Risk

Thanks to advancements in technology, manufacturers are increasingly using computer-based controls in their equipment and machines. These can be programmed to lock out the machine or equipment. This is necessary during minor repairs and servicing because they require constant energization. Built-in technology can help prevent and reduce electrical injuries and fatalities by designing out electrical hazards and risks.

Over the last few years, the Occupational Safety and Health Administration (OSHA) has also been exploring whether modern technology can effectively protect workers from hazardous energy.

OSHA issued a Request for Information (RFI) in May 2019 to understand the strengths and limitations of this new technology as well as the potential hazards to workers. The comment period ended in August 2019. In the years since, employers continue to wait patiently, anticipating OSHA’s Advance Notice of Proposed Rulemaking (ANPR) on the issue. Meanwhile, employers continue to deal with four lockout/tagout (LO/TO) problem areas.

Like most OSHA regulations, the Control of Hazardous Energy (lockout/tagout) standard (§1910.147) uses common sense principles to protect employees. To ensure safe work, the standard requires written energy control procedures, employee training and periodic inspections. However, four problem areas cause quite a bit of confusion:

  • Applying the “minor servicing” exemption,
  • Using a single energy control procedure for multiple machines,
  • Training for work that involves electrical hazards, and
  • Periodic inspections for multiple control procedures.

Let’s explore these further so you can learn how to keep workers safe from electrical energy hazards. I will also share real-world examples of LO/TO done right—and wrong

LOTO (Lockout/Tagout)

Minor Service vs. Lockout Procedure

The standard includes a minor servicing exception that allows for certain maintenance work without using LO/TO where these tasks can be done safely. Examples might include clearing jams, applying lubrication or replacing a worn belt.

To qualify for the exception, the work must:

  1. Take place during normal production operations;
  2. Be routine, repetitive and integral to the use of the equipment for production; and
  3. Be performed using alternative measures, such as machine guards, that provide effective protection.

If a maintenance task does not meet all three criteria, it is not exempt. Employers often assume that a task is exempt when it requires lockout procedures. Clearing a jam might be a normal part of production, but if doing so puts an employee at risk or requires removing or bypassing fixed guards, it probably does not qualify for the exemption.

A common violation involves work that exposes the employee to hazardous energy or points of operation. Sadly, this discovery is often made when an employee gets injured, possibly losing a finger—or worse.

To avoid the lockout/tagout requirements during minor service, you must protect employees using guards or other measures that allow them to safely perform the service without being exposed to hazardous energy. Review any routine maintenance work to verify that it meets the exemption. If workers perform regular service that does not meet all three criteria, you need to develop LO/TO procedures.

Using One Procedure for Multiple Machines

Much of the time, you need to develop a unique procedure for each machine. But sometimes, similar machines often use similar energy control procedures, and a single procedure can work for more than one machine. In these instances, a generic energy control procedure with supplemental checklists can meet the OSHA standard.

Machines or equipment that use the same type and magnitude of energy—and that have the same or similar controls—can be covered with a single procedure. However, the procedure must include enough detail and provide enough direction so employees can follow it and safely perform their work. If the procedure is too generic, it will not be useful.

To be covered by one procedure, the machines or equipment must have the same:

  • Specific procedural steps for shutting down, isolating, blocking and securing them to control hazardous energy;
  • Specific procedural steps for the placement, removal and transfer of lockout/tagout devices and the responsibility for them; and
  • Specific requirements for testing to determine and verify the effectiveness of lockout/tagout devices and other control measures.

Although you can use one set of procedures for multiple machines, the procedure must provide instructions that specify a step-by-step approach for each machine. OSHA will carefully examine the procedure of any employer that claims only one procedure is adequate. If you have multiple machines that use the same procedure, verify that the above criteria are met to ensure compliance and to protect your workers.

Training to Handle Electrical Hazards

Workers who perform lockout/tagout require training as authorized employees under the standard. However, an authorized employee cannot verify that an electrical circuit is de-energized. Doing so requires training as a qualified person under the Electrical Safety-Related Work Practices standard. The training requirements can be found in §1910.332. The definition of a qualified person notes that whether a person is qualified depends on the circumstances and the equipment involved. It is possible for an individual to be “qualified” on certain equipment in the workplace, but “unqualified” on other equipment.

If you have workers who face electrical hazards during servicing or maintenance, ensure they have training as required by the electrical safety standards. Training as an authorized employee under the LO/TO standard is not sufficient when electrical energy is a hazard. Under LO/TO, an authorized employee is controlling hazardous energy but if work must be performed while live power is present, additional electrical safety training is necessary to ensure the authorized employee is qualified to do so.

The energy control procedure for equipment with electrical hazards should include steps to safely lockout all energy sources. However, the electrical safety regulations require a qualified person to verify that the equipment is de-energized.

Inspecting Groups of Procedures

The lockout/tagout standard requires periodic inspections of each energy control procedure, at least once a year. As noted above, sometimes a single procedure covers multiple machines. The next step is to determine whether a single audit will meet this requirement, or if you need multiple audits for each variation.

OSHA, in a Letter of Interpretation dated March 9, 2004, stated that you could group related procedures for similar equipment when conducting inspections. Grouping procedures are allowed if all procedures in the group have the same or similar use and follow the same procedural steps. In other words, if you use one procedure for multiple machines, as described above, you can treat this as one procedure for your annual or periodic inspection.

If you categorize machines and equipment, you must inspect a representative number of authorized employees performing the procedure within each category. The sampling must reasonably reflect plant maintenance operations and energy control practices for the procedure being inspected. If you group procedures, select different machines from the group for evaluation each year. This way, over time, each individual machine will eventually be inspected.

Not following these often-misunderstood provisions of the lockout/tagout standard could put your employees at risk. Proper training, safety procedures and safety inspections can help you prevent accidents and keep your employees safe.

Source: EHS Today