Staying Safe During Equipment Maintenance

Lockout/tagout ranked fifth on OSHA's list of the Top Ten most-violated standards during fiscal year 2017 and again in FY2018. There were 2,877 violations of 1910.147 during FY2017 and 2,944 during FY2018.

• By Jerry Laws
• Dec 01, 2018

Lockout/tagout, known as LOTO, is the concept of controlling hazardous energy, usually in order to service or perform maintenance on machinery. Planning the work, identifying all energy sources to be controlled and the means for verifying disconnection, training employees and supervisors on the procedures to follow to ensure they work safely, and providing the necessary devices and equipment—locks, tags, etc.—should be addressed in the employer's written LOTO plan for carrying out the work.

Appendix A of OSHA's 1910.147 lockout standard offers a simple lockout procedure that the agency says could benefit employers as they develop their procedures, so that they'll meet the standard's requirements. The appendix explains when tagout may be used—only when the energy-isolating devices are not lockable and the employer complies with the standard's provisions requiring additional training and more rigorous, periodic inspections.

The procedure establishes the minimum requirements for lockout of energy-isolating devices. It lists a sequence of steps to follow, beginning with notifying all affected employees that servicing or maintenance is required on a machine or on equipment that must be shut down and locked out. The procedure says, "All employees are required to comply with the restrictions and limitations imposed upon them during the use of lockout. The authorized employees are required to perform the lockout in accordance with this procedure. All employees, upon observing a machine or piece of equipment which is locked out to perform servicing or maintenance shall not attempt to start, energize, or use that machine or equipment."

Other steps in the sequence include having the authorized employee:

• refer to the company's procedure to identify the type(s) and magnitude of energy the equipment utilizes,
• understand the hazards of the energy, and
• know the methods to control the energy.

Next, if the machine or equipment is operating, it should be shut down by the normal stopping procedure, then the energy-isolating device(s) should be locked out with assigned, individual locks, and stored or residual energy must be dissipated or restrained by methods such as grounding, repositioning, blocking, bleeding down, etc., it states.

The authorized employee is then to ensure the machine is disconnected from the energy source(s) by first checking that no personnel are exposed, then verifying the isolation of the equipment by operating the push button or other normal operating control(s) or by testing to make certain the equipment will not operate. ("Caution: Return operating control(s) to neutral or 'off' position after verifying the isolation of the equipment," it warns.)

When all of this is done, the machine is locked out.

Restoring Machinery to Service
Restoring the machine or equipment to service following servicing or maintenance takes fewer steps:

• Check the machine/equipment and the immediate area around it to make sure non-essential items have been removed and components are operationally intact.
• Check the work area—have all employees been safely positioned or removed from the area?
• Verify the controls are in neutral.
• Remove the lockout devices and re-energize the machinery.
• Notify affected employees that the servicing or maintenance work is completed and that the machine or equipment is ready for use.

An OSHA online tutorial¹ about lockout/tagout stresses an important point about the step where lockout devices are removed after servicing or maintenance work is finished: Each lock or tag must be removed from the energy-isolating device by the worker who applied it [29 CFR 1910.147(e)(3)].

The tutorial explains the circumstance that allows an employee other than the one who applied a LOTO device to remove it: "When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures and training for such removal have been developed, documented, and incorporated into the employer's energy control program."

The employer must take these steps if an employee other than the one who applied the device removes it:

• The employer must verify that the authorized employee who applied the device isn't at the facility.
• The employer must make all reasonable efforts to contact the authorized employee to inform that person that the device has been removed.
• The employer must ensure that the authorized employee knows the lockout device has been removed before he or she resumes work at the facility.

29 CFR 1910.147(f)(4) directs employers to ensure "the continuity of employee protection" amid shift or personnel changes. They must provide for the orderly transfer of lockout or tagout protection between employees as they are going off and coming on duty, it states.

The NORA Resource Guide
A new online resource from NIOSH is a step-by-step guide, the "Hazardous Energy Control (Lockout and Other Means) Resource Guide," that offers sample materials and templates to help users implement the elements needed for successful LOTO program. Members from the National Occupational Research Agenda Manufacturing Sector Council reviewed, adapted, and compiled the resources in it.

"It is a matter of life and death," NIOSH noted on the page where the guide is posted. "Hazardous energy control is more than Lockout. It encompasses Machine Guarding, Alternative Measures (alternative guarding arrangement that prevents exposure to hazardous energy), Lockout, and other methods of ensuring worker safety from contact with hazardous energy."

The guide² covers four main activities needed for a successful program: energy control procedures; employee training; auditing or conducting periodic inspections; and specifying, acquiring, or designing equipment that will accommodate lockout procedures. The four "work best when they are documented in the form of a written procedure," the agency pointed out.

Significant Penalties for LOTO Violations
Lockout/tagout ranked fifth on OSHA's list of the Top Ten most-violated standards during fiscal year 2017. There were 2,877 violations of 1910.147 during that fiscal year, an OSHA Directorate of Enforcement official announced during the 2017 National Safety Council Congress & Expo. (During the 2018 Congress & Expo, OSHA announced that LOTO also ranked fifth in fiscal 2018, with 2,944 citations issued during that fiscal year.)

The agency frequently announces LOTO enforcement actions with large penalties:

• OSHA announced an enforcement case with $107,168 in proposed penalties Oct. 1, 2018, against an Ohio plastics manufacturer that allegedly exposed employees to amputation hazards. One citation ($12,934 in penalties) alleges the company committed a serious violation by not ensuring periodic inspections of the energy control procedure were conducted at least annually on three hydraulic presses, and that employees didn't follow all steps required for control of hazardous energy before they changed dies in the presses. Another citation in the case, with an identical penalty, alleges a serious violation of 29 CFR 1910.147(d) at the facility because the established procedure for application of energy control did not cover the actions listed in that section of the standard and were not done in sequence as it requires. OSHA also cited the company for a repeat violation, with $71,137 in penalties assessed, for not providing adequate training to ensure employees understood the purpose and function of the energy control program. OSHA had cited the company for the same violation once before, with the citation affirmed as a final order in August 2015.
• Another enforcement case announced in October 2018 brought even larger proposed penalties against a pet food manufacturer in New Jersey, a total of $152,829, for similar violations, along with other violations related to fall protection, respiratory protection, and powered industrial trucks. OSHA asserted that the manufacturer failed to develop, document, and utilize procedures for controlling hazardous energy when employees were engaged in servicing or maintenance on blend mixing machinery and the associated electric and pneumatic equipment.
• An enforcement case announced Sept. 27 against a Wisconsin company mainly concerned machine guarding violations and fall hazards, but OSHA also cited the employer for not developing lockout/tagout procedures as required, not de-energizing a machine prior to an employee's attempt to clear a jam, and not implementing the necessary energy control measures—machine isolation, applying a LOTO device, dissipating residual energy, and verifying machine isolation—to protect the worker. Penalties proposed in this case totaled $221,726.

References
1. https://www.osha.gov/dts/osta/lototraining/tutorial/tu-overvw.html
2. https://www.cdc.gov/nora/councils/manuf/loto/guide.html

This article originally appeared in the December 2018 issue of Occupational Health & Safety.