Elements of a Lockout/Tagout Program OSHA

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1 September 15, 2015 Elements of a Lockout/Tagout Program OSHA Dayna Noble Industrial Safety Consultant Specialist Ohio BWC Dayna.noble@bwc.state.oh.us

2 Top 10 most frequently cited OSHA standards violated in FY2014 Federal OSHA in fiscal year 2014 (Oct 1, 2013 Sep 30, 2014): 1. Fall protection, construction (29 CFR ) 2. Hazard communication standard, general industry (29 CFR ) 3. Scaffolding, general requirements, construction (29 CFR Respiratory protection, general industry (29 CFR ) 5. Powered industrial trucks, general industry (29 CFR ) 6. Control of hazardous energy (lockout/tagout), general industry (29 CFR ) 7. Ladders, construction (29 CFR ) 8. Electrical, wiring methods, components and equipment, general industry (29 CFR ) 9. Machinery and Machine Guarding, general requirements (29 CFR ) 10. Electrical systems design, general requirements, general industry (29 CFR )

3 Why Lockout a Machine? Employee crushed to death in garbage compactor (2013) A 37-year-old escalator mechanic died when he was crushed in an escalator while performing maintenance. (2011) 21-year-old temporary worker was killed during his first day on the job at a bottling plant in Florida while cleaning glass from under the hoist of a palletizing machine. (2013) Employee was clearing a cardboard jam from the facility s conveyor belt system, and the energy source for the machine wasn t locked out. This resulted in the amputation of the worker s fingers. (2013)

4 References OSHA Standard Interpretation letters Lockout/ Tagout OSHA Compliance Directive B11.19 Safeguarding Machine and Equipment NFPA Electrical Standard for Industrial Machinery ANSI/ASSE Z Control of Hazardous Energy Lockout/Tagout and Alternative Methods

5 Scope of this Standard This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy.

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7 Servicing and Maintenance Generally requires the stoppage of the machine or equipment and the production process. The machine or equipment must be isolated from the energy source and the energy isolating device disabled. Employees are exposed to the unexpected energization, startup or release of stored energy against which the control procedures established in this standard are designed to provide protection. 7

8 Application of this Standard This standard applies to the control of energy during servicing and/or maintenance of machines and equipment. Does Not Apply to: Work on cord and plug connected electric equipment Hot tap operations

9 Application Normal production operations are not covered by this standard. Servicing and/or maintenance which takes place during normal production operations is covered by this standard only if: 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 (See Subpart O of this Part).

10 Minor Servicing Is 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

11 Minor Servicing There are some activities which are properly classified as servicing or maintenance but which are often performed during normal production operations. These activities include lubricating, cleaning, un-jamming, and making minor adjustments and simple tool changes. 11

12 What Minor Servicing Is NOT Work performed BEFORE normal production operations begin. Adjustments made during set-up as producing has not yet begun The replacement of machine or equipment components -- such as belts, valves, gauges, linkages, support structure, etc. because it cannot be safely accomplished when a machine or piece of equipment is operating.

13 Minor Servicing Because these situations are addressed on a case by case basis due to numerous variables, there are no exact or black and white solutions to apply across the board; The employer must, at a minimum, perform a risk assessment on the process to determine hazards present, employee exposure and possible exposure, and means to control the hazards or prevent exposure. Employer MUST be able to justify applying the exception

14 Purpose of this Standard This section requires employers to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees.

15 General Requirements Written Energy Control Program Written Energy Control Procedures Protective materials and hardware Periodic inspection Training and communication Application of control Release from lockout or tagout Testing or positioning of machines, equipment or components Outside personnel (contractors, etc.). Group lockout or tagout Shift or personnel changes.

16 Written Program Written Program required by the standard Covers specific elements of the standard specify procedural steps detail testing of machine for verification Lockout device removal Outside Personnel Group Lockout Shift Personnel changes

17 Machine Specific Procedures Must be developed, documented and utilized If machinery or pieces of equipment are similar, one procedure will cover all like pieces Shall be readily available to employees. One practice is to post at the machine.

18 Contents of a Procedure Equipment Lockout Steps Notify Affected Employees Shut Down Isolate Hazardous Energy sources (apply locks/tags) Block/Jack/Pin mechanical energy sources Release stored energy bleed, drain apply grounds Test for Zero Energy Removing Lockout Search for and removed personnel, tools, loose parts Replace safe guards Remove locks Notify Affected employees 18

19 Hardware Supplied by the Employer Standardize all Locks and Tags Identify the User Must be Durable Used ONLY for Lockout/Tagout

20 Periodic Inspections Inspect all procedures annually Include all authorized employees in the inspection Document: Date of Inspection Machine or Process to be reviewed Names of person doing the Inspection Inspection document is kept on record for review

21 Training Requirements Authorized Employees Types of energy Magnitude of energy sources Locations & how to lockout energy sources Types of devices to be used. Affected and Other Employees Purpose of the Program Types & how to identify devices To understand that they do not tamper with devices Certification must include: Each employee s name Dates of training

22 Retraining Requirements For Affected and Authorized Job assignment changes Changes in machines, equipment, processes that present a new hazard Changes to procedures When a periodic inspection reveals retraining is necessary Whenever an employer has reason to believe deviations from the procedures has occurred

23 Application of Controls Energy Isolating Device or Control Circuitry EID: A mechanical device that physically prevents the transmission or release of primary energy Disconnect switch, line valve, block, or manually operated circuit breaker CC: A type of circuit that uses control devices to determine when loads are energized or de-energized by controlling current flow (secondary energy). Push buttons, selector switches, interlocks, emergency stop buttons these circuits can fail to control the energy 23

24 Application of Controls Verification of isolation Prior to starting work on equipment that has been locked/tagged out, the authorized employee shall verify that isolation and deenergization of the machine or equipment have been accomplished. Lock Tag Try.and Test! 24

25 Lockout Device Removal Each device shall be removed by the employee who applied the device Exception: If authorized employee is not available to remove device then device may be removed under the direction of the employer Employer must provide specific documented procedures and training for device removal (include in written program)

26 Testing and Positioning of Equipment Testing or positioning of equipment when devices must be removed, the following sequence of actions shall be followed: 1. Clear the equipment of tools and materials 2. Remove employees from the equipment 3. Remove the lockout/tagout devices 4. Energize and proceed with testing/positioning (must still provide effective protection ) 5. De-energize and reapply energy control measures

27 Outside Personnel Contractors, outside service personnel, etc. The on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures. The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer's energy control program.

28 Group Lockout/Tagout Working in Groups: Must provide equivalent level of protection for all employees Each authorized employee shall attach his/her lock or use a lock box With more that one crew, there will be a PRIMARY AUTHORIZED PERSON to coordinate all the efforts 28

29 Shift or Personnel Changes Procedures must be utilized during shift and personnel changes to ensure: Orderly transfer of lockout or tagout device protection between shifts Minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.

30 Five Mistakes That Can Cause Injury During a Lockout/Tagout 1. Failure to stop equipment - Some workers feel that productivity will suffer if they take the time to stop/restart equipment. Others feel that their experience with the equipment gives them the ability to work on it without having to safeguard it. Both attitudes can be fatal. 2. Failure to disconnect from the power source - One of the most common misconceptions among workers is that merely flipping the on/off switch on electrical equipment is all that is necessary to be safe. They never consider the fact that the switch may be defective or that power can still come through a short circuit.

31 Five Mistakes That Can Cause Injury During a Lockout/Tagout 3. Failure to drain residual energy - Many electrical devices store power in a capacitor or battery. There is still the risk of being shocked by the equipment even after the plug has been removed from the electric outlet. A hot pipe, or a pressurized tank continues to carry energy, even when the initial source of that energy is disconnected. All stored energy must be completely blocked or released if workers are to be safe. 4. Failure to confirm that co-workers are not in the path of danger before restarting - There is a high incidence of workers causing injury to their fellow employees by restarting machines before making sure that it is safe to restart.

32 Five Mistakes That Can Cause Injury During a Lockout/Tagout 5. Failure to clear work areas before restarting - A repair tool left in the works to fly out and hit someone can be as big a hazard as not locking out the machine.

33 Evaluate your Program Develop and implement a written hazardous energy control program review annually Develop lockout/tagout procedures specific to each machine in the facility. Evaluate your job processes. Operators may be performing tasks that fall under LO/TO. Provide training to all authorized employees.

34 Evaluate your Program Be sure that workers have a clear understanding of when hazardous energy control procedures apply and training on how to properly apply the procedures. Ensure that workers are provided with a sufficient amount of locks, tags, and any other hardware that may be necessary. Clearly label isolation devices, such as breaker panels and control valves.