e-book MULTI-SYSTEM OSHA LOCKOUT EXAMPLE 1 (OSHA LOCKOUT EXAMPLES)

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Technically, OSHA may not cite the same conduct as a concurrent violation of both standards. Specifically, we have found that employers do a very good job of addressing hazardous electrical energy in their LOTO programs, but LOTO applies to every type of hazardous energy, including mechanical, thermal, hydraulic, pneumatic and gravity. That means employers must ensure employees who are performing servicing or maintenance on an industrial oven are protected from heat energy, that employees repairing a power press are protected from the gravity forces of a press in the upright position, and employees fixing a piece of air-powered equipment are safeguarded from an unanticipated release of air.

Engineering Basics: Why Interlock Guards Trump Lockout/Tagout | Machine Design

That means that even while an employee is performing maintenance in the guts of a machine, LOTO is not required if employees would become aware the machine was about to energize. For example, if the machine automatically sounds an alarm flashes strobe lights for several seconds before a piece of equipment begins to operate, and there is no mechanical way for those warnings to be defeated, then it cannot be said that energization is unexpected. It is well understood and its impact on operations is significant. Such a change, however, is far from non-controversial, is certainly not minor and does not clarify any present confusion about application of the standard.

What Is Lockout Tagout?

Employers should ensure their MSPs clearly and specifically outline the steps to be followed. Put another way, compliant MSPs provide sufficient specificity to guide the employee through the lockout process. Over-generalization can result in a document that has little or no utility to the employee who must follow the procedure. The real challenge seems to be ensuring LOTO procedure are machine-specific; i.

Employers may, however, develop a single MSP for a group of similar machines that have the same hazardous energy source s and the same or very similar methods for controlling that energy. If employers are using one procedure for a group of machines, they should consider an inset or note in the MSP that highlights any unique aspects for each piece of equipment e. Contract work also presents some issues in connection with machine-specific LOTO procedures.

How to Assess Your Safety Processes

But if a host employer never services its equipment in-house, the host need not develop its own machine-specific LOTO procedures. Misunderstanding or Forgetting Periodic Inspections. Employers, in addition to having effective machine-specific LOTO procedures, must conduct periodic inspections of each energy control procedure to avoid a citation under These inspections must be performed at least annually to ensure energy control procedures continue to be implemented properly, and that affected employees are familiar with their responsibilities under the procedures.


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Many employers neglect to carry out these LOTO inspections each year, but more often, employers fail to conduct them in the manner contemplated by the LOTO standard. To satisfy the standard, a periodic inspection must:. The individual conducting the inspection must observe the implementation of the energy control procedures and discuss the procedures with the employees implementing them to determine that the requirements of the LOTO standard are understood and are being followed by the implementing employees.

While the designated inspector need not observe every authorized employee implementing every machine-specific LOTO procedure for which he or she is authorized to service, the inspector must observe a representative number of employees implementing the procedures. The designated inspector must, however, talk with each LOTO authorized employee, even those not implementing the procedure during the inspection.

Relying on a group meeting - such as a toolbox talk - where energy control procedures are reviewed will not suffice unless actual implementation of the procedure is inspected in real time. Employers can, in the interest of efficiency, inspect groups of procedures provided the employer performs a case-by-case assessment to determine whether the procedures can be effectively inspected as a group. Once the periodic inspections are completed, the employer must ensure any deficiencies or deviations are corrected. The employer must also certify, in writing, the inspection was performed.


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  8. To comply with the standard, a certification must include the machine or equipment on which the inspection was conducted, the date of the inspection, the employees included in the inspection, and the name of the inspector who performed the inspection. Some employers conduct the inspections every 10 months to reduce the likelihood of an error or omission.

    Employers should keep in mind that if they have procedures that are used less than once per year, those should be inspected each time they are used. The real rub in getting the minor servicing exception right is understanding, implementing and demonstrating that the measures taken as a substitute to locking out the machine are effective to protect employees from hazardous energy. Some examples OSHA endorses here are use of interlocks, local disconnects in the exclusive control of the servicing employee or specially designed tools that keep the employee out of the zone of danger.

    We have found that employers typically do a very good job of training those employees tasked with performing service and maintenance i. It is well understood and its impact on operations is significant. Such a change, however, is far from non-controversial, is certainly not minor and does not clarify any present confusion about application of the standard.

    Employers should ensure their MSPs clearly and specifically outline the steps to be followed. Put another way, compliant MSPs provide sufficient specificity to guide the employee through the lockout process. Over-generalization can result in a document that has little or no utility to the employee who must follow the procedure. The real challenge seems to be ensuring LOTO procedure are machine-specific; i. Employers may, however, develop a single MSP for a group of similar machines that have the same hazardous energy source s and the same or very similar methods for controlling that energy.

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    Eight Steps for Safer Lockout/Tagout Programs

    If employers are using one procedure for a group of machines, they should consider an inset or note in the MSP that highlights any unique aspects for each piece of equipment e. Contract work also presents some issues in connection with machine-specific LOTO procedures. But if a host employer never services its equipment in-house, the host need not develop its own machine-specific LOTO procedures.


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    Misunderstanding or Forgetting Periodic Inspections. Employers, in addition to having effective machine-specific LOTO procedures, must conduct periodic inspections of each energy control procedure to avoid a citation under These inspections must be performed at least annually to ensure energy control procedures continue to be implemented properly, and that affected employees are familiar with their responsibilities under the procedures. Many employers neglect to carry out these LOTO inspections each year, but more often, employers fail to conduct them in the manner contemplated by the LOTO standard.

    To satisfy the standard, a periodic inspection must:. The individual conducting the inspection must observe the implementation of the energy control procedures and discuss the procedures with the employees implementing them to determine that the requirements of the LOTO standard are understood and are being followed by the implementing employees. While the designated inspector need not observe every authorized employee implementing every machine-specific LOTO procedure for which he or she is authorized to service, the inspector must observe a representative number of employees implementing the procedures.

    The designated inspector must, however, talk with each LOTO authorized employee, even those not implementing the procedure during the inspection. Relying on a group meeting - such as a toolbox talk - where energy control procedures are reviewed will not suffice unless actual implementation of the procedure is inspected in real time.

    Employers can, in the interest of efficiency, inspect groups of procedures provided the employer performs a case-by-case assessment to determine whether the procedures can be effectively inspected as a group. Once the periodic inspections are completed, the employer must ensure any deficiencies or deviations are corrected.

    Typical Lockout Tagout Procedures

    The employer must also certify, in writing, the inspection was performed. To comply with the standard, a certification must include the machine or equipment on which the inspection was conducted, the date of the inspection, the employees included in the inspection, and the name of the inspector who performed the inspection.

    Some employers conduct the inspections every 10 months to reduce the likelihood of an error or omission.

    Brady Toolbox Talks Lockout Tagout #1: Which LOTO Standards Does OSHA Scrutinize Most?

    Employers should keep in mind that if they have procedures that are used less than once per year, those should be inspected each time they are used. The real rub in getting the minor servicing exception right is understanding, implementing and demonstrating that the measures taken as a substitute to locking out the machine are effective to protect employees from hazardous energy.

    Types of Hazardous Energy

    Some examples OSHA endorses here are use of interlocks, local disconnects in the exclusive control of the servicing employee or specially designed tools that keep the employee out of the zone of danger. We have found that employers typically do a very good job of training those employees tasked with performing service and maintenance i.

    To satisfy the LOTO standard, training should ensure affected and other employees understand the purpose and function of the energy control program and procedures, know when the procedures are being used and to be aware of the prohibition against attempting to restart a machine that is locked out. If it is necessary to assign temporary workers to perform service or maintenance tasks, it is essential that those workers receive the same training given to permanent LOTO authorized employees. Even if the temporary workers are merely operating equipment, or more likely, will work in the area where LOTO is utilized, they must be trained to the level of affected or other employees.

    Employers should never assume the staffing agency sending the temporary workers provided that training; the host employer should trust and verify or provide the training directly. Even when the staffing agency has provided LOTO training to temporary workers, the host employer is presumed to have knowledge of unique, site-specific hazards, and so will generally be expected by OSHA to provide additional training specific to its workplace and equipment.