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Lockout / Tagout

TRAINING

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What is 1910.147?

• OSHA standard for Lockout /Tagout• Goal: Control the release of hazardous energy

during maintenance and servicing• Many types of energy:

– Mechanical

– Hydraulic

– Electrical

– Gas

– Pneumatic

– Water

– Chemical

– Thermal

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Agenda

• Why We Do It?

• What is required for compliance?

• How to get started with Lockout/Tagout?

• References

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Risk Mitigation

Financial

Employee Safety Legal

Risk

Mitigation

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Employee Safety

• Approximately 3 million workers in the US service equipment and face the greatest risk of injury if Lockout/Tagout is not properly implemented

• Lockout/Tagout prevents an estimated 120 fatalities and 50,000 injuries each year in the US.

Source: http://www.osha.gov/SLTC/controlhazardousenergy/index.html

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Legal Risk

• Created under the Occupational Safety and Health Act of 1970

• Only government regulatory agency for workplace safety

• Instructs, conducts inspections and enforces workplace safety

• Does not apply to government facilities

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Legal Risk

OSHA General Duty Clause States:

“each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”

Source: OSHA 29 USC 654

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Legal Risk

• 29 CFR 1910.147 was adopted in 1989 and established minimum performance requirements for the control of hazardous energy

• The lockout/tagout standard applies to general industry employment

• It covers the servicing and maintenance of machines and equipment in which the unexpected start-up or the release of stored energy could cause injury

• It covers about 39 million workers

OSHA Standard 29 CFR 1910.147:

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Legal Risk

“covers electrical safety-related work practices and procedures for employees who work on or near exposed energized electrical conductors or circuit parts in workplaces that are included in the scope of this standard”

“Intended to provide for employee safety relative to electrical hazards in the workplace”

NFPA 70E – Chapter 1 Article 110 States:

Source: NFPA Regulations – Chapter 1, Article 110, 2004

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Legal Risk

• Required by law for employers to follow

• Requirements in General Terms

• Lots of details but also rely on consensus industry standards for guidelines

NFPA 70E – 2004 (Originated 1976):

• Details – safe installation, maintenance and work practices, signs, PPE (Personal Protective Equipment)

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Financial Risk

Downtime

• Personnel

• Equipment

Legal Action

• Liability and Injury

• Cost of outside counsel

Fines and Penalties:

• LOTO is #3 most cited by OSHA

• Fiscal Year 2006 38,579 federal OSHA site inspections

58,058 state OSHA site inspections

3,659 violations for LOTO totaling about $6MSource: Occupational Hazards, February 2008

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Financial Risk

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Risk Mitigation

Conclusion:

“The costs in terms of human suffering, lost productivity, worker’s compensation claims and lawsuits can far outweigh the investment in a comprehensive program.”

Source: Occupational Health&Safety Volume 76, Number 10

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What is required?

Elements of an effective Lockout/Tagout program:

Procedures

Training

Device requirements

Inspections

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Procedures

OSHA 1910.147(c)(4)(i)“Procedures shall be developed, documented and utilized

for the control of potentially hazardous energy when employees are engaged in the activities covered by this section”

NFPA 70E 120.2 (F) / Ch. 5-4“The employer shall maintain a copy of the procedures

required by this section and shall make procedures available to all employees”

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Procedures

Standards/Codes: OSHA 1910.147(c)(4); NFPA 70E - Article 120.2 (D) & (F), and Annex G

Procedures shall be developed, documented and utilized for the control of potentially hazardous energy:

– Steps to de-energize and re-energize

– Lockout/Tagout devices to utilize

– Drawings/diagrams (equipment specific)

– What employees are exposed to hazards?

– Who is qualified to perform LOTO?

– Who is in charge of the LOTO program?

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Procedures

Steps for equipment shutdown

1. Prepare for and announce shutdown

2. Shutdown equipment

3. Disconnect energy sources / test for isolation

4. Lockout and/or Tagout

5. Release stored energy

6. Verify isolation

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Procedures

Steps for equipment startup

1. Verify equipment operationally intact - Clear all personnel and tools

2. Ensure employees are safely positioned

3. Remove lockout/tagout devices from each energy-isolating device

4. Notify all affected employees of Lockout/Tagoutremoval and that work has been completed

5. Start equipment

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Training

OSHA 1910.147(c)(7)(i)“The employer shall provide training to ensure that the purpose and

function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees”

NFPA 70E 120.2 (B) (2)“Each employer shall provide training as required to ensure

employees’ understanding of the lockout/tagout procedure content and their duty in executing such procedures”

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Training

Authorized employees – person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment

Affected employees – employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under Lockout or Tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed

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Training

Authorized employees: Recognition of applicable hazardous

energy sources

Type and magnitude of energy available in the workplace

Methods and means necessary for energy isolation and control

Ways to verify that the energy isolation is effective

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Training

Affected employees:

Instructed in the purpose and use of energy control procedure

Should never attempt to restart or re-energize machines or equipment which are locked out or tagged out

Respect use of warning tags

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Q: When Should a Company Retrain?

New employees, or change in employee responsibilities

New equipment, or change in machines, equipment or processes that present a new hazard or change to energy control procedures

Deviations from, or inadequacies in, the employee’s knowledge or use of the energy control procedure

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Device Requirements

OSHA 1910.147(c)(7)(i)“Lockout device – a device that utilizes a positive means such as

a lock, either key or combination type, to hold an energy isolating device in a safe position and prevent the energizing of a machine or equipment”

NFPA 70E 120.2 (E) (2)“Each employer shall supply, and employees shall use,

lockout/tagout devices and equipment necessary to execute the requirements of 120.3(E). Locks and tags used for control of exposure to electrical energy hazards shall be unique, shall be readily identifiable as lockout/tagout devices, and shall be used for no other purpose.”

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Device Requirements

Lockouts must be:

Used only to control energy Durable enough for use in their

environment Standardized by either color, shape or size Substantial – withstand all but excessive

force Identify the employee applying the device

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Device Requirements

Tags must be:

Durable enough for use in their environment

Substantial – enough to resist accidental or inadvertent removal

Standardized by either color, shape or size

Identify the employee responsible for the Tagout

Non-reusable attachment device & attachable by hand

Withstand 50 lbs of force

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Inspection

OSHA 1910.147(c)(6)(i)“The employer shall conduct a periodic inspection of the energy

control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.”

NFPA 70E 120.2 (C) (3)“An audit shall be conducted at least annually by a qualified person

and shall cover at least one Lockout/Tagout in progress and the procedure details. The audit shall be designed to correct deficiencies in the procedure or in employee understanding.”

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Inspection

At least annually

Performed by authorized employee, other than the one(s) using the energy control procedure

Cover Lockout/Tagout in progress

Between inspector and authorized/affected employees• Lockout – review employees responsibilities under the

energy control procedure inspected

• Tagout – review employee responsibilities and Tagoutlimitations

Document inspection

Correct any deviations or inadequacies identified

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Outside Personnel

• Example: Contractors

• “On-site employer and outside employer shall inform each other of their respective lockout or tagout procedures”

• “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”

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Group Lockout/Tagout

OSHA 1910.147(f)(3)(i)“When servicing or maintenance is performed by a crew, craft,

department or other group, they shall utilize a procedure which affords the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device”

ONE authorized employee is responsible for overall procedure in the crew.

If multiple crews are involved, there must still be an overall authorized employee responsible.

Group Lockout devices such as Group Lockboxes and/or hasps must be used.

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Shift or Personnel Changes

• “Ensure continuity of lockout or tagout protection”

• Employee from incoming shift MUST apply his/her lockout device before employee from outgoing shift removes his/her device.

• Communicate about the work that has been done

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Unavailable Employee

• If authorized employee is not available to remove his device, then the employer may remove it IF:– Employer has procedures and training for such

removal in energy control program– Verification that authorized employee is not at

the facility– Making all reasonable efforts to contact

authorized employee to inform him/her that lockout device has been removed

– Ensuring that authorized employee is aware that his device was removed before resuming work at that facility

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How to establish an energy

control program?

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The whole process

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Conduct a hazard assessment by

identifying all equipment that is used, serviced, maintained or stored

1. Assessment

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Determine Lockout/Tagout requirements for all equipment, identifying and documenting all energy sources – and create machine-specific procedures containing:

Type of Hazard

Location on the equipment

Proper isolation and lockout device/procedure

How to dissipate the stored energy

How to verify the isolation

After this step, you should have an energy control program for your facility and machine-specific procedures

2. Procedures

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Circuit Breakers Electric Plug Toggle Switch Rocker Switch Cable Lockout

Pneumatic Ball valve Gate Valve Group Lock Box Tags

LOTO Stations LOTO Kits Hasps Padlocks Other

3. Devices

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A. Train all employees in facility Authorized employees:

• Recognition of applicable hazardous energy sources

• Type and magnitude of energy available in the workplace

• Methods and means necessary for energy isolation and control

• Ways to verify that the energy isolation is effective

Affected and Other employees:• Instruction in the purpose and use of energy

control procedure• Should never attempt to restart or re-energize

machines or equipment which are locked out or tagged out

• Respect use of warning tags

B. Document the training

4. Training

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Processes need to be put in place to maintain the comprehensive program for the following:

Periodic Inspections must take place at least annually to identify and correct any deviations or inadequacies.

Retraining must take place anytime there is a change in responsibilities, equipment or procedures along with new employees

5. Processes

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In conclusion…

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Key Take-Aways

1. Only work on equipment “hot” or “live” if it absolutely unavoidable

2. Lockout over Tagout

3. Facility specific and machine specific

4. Don’t forget about secondary energy sources or stored energy

5. Use annual inspections, regular training (annually suggested), and discipline to avoid complacency

6. Lockout/Tagout is only one part of a complete and effective safety program (safety ID, PPE, etc.)

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References

OSHA 1910.147 NFPA 70E (2009) NEC 2008 www.osha.gov www.nfpa.org Your company Lockout/Tagout procedure