#8 Lockout Tagout (LOTO): Examining Top OSHA Violations of 2013

General Industry Regulation 1910.147, The Control of Hazardous Energy – better known as Lockout/Tagout (LOTO) – was the seventh most violated standard in 2013 with 3,254, more than twice as many as in 2012 (1,572).

To avoid your business getting into trouble in 2014, pay attention to these four elements of the hazard that OSHA has identified as “hot topics” because of the potential to get on the wrong side of the law.

1. Relationship of LOTO standard to Subpart O, Machinery and Machine Guarding Standards
2. Energy Control Program
3. Group Lockout/Tagout
4. Multiple Energy Sources/Multiple Items of Equipment

1. Machine Guarding

LOTO provides protection from unexpected energization, start up, or release of stored energy while servicing or maintaining equipment. Subpart O provides hazardous energy protection during normal work.

But when an employee must remove or bypass machine guarding, or place part of his body into a hazardous area to service equipment during normal production, then the LOTO standard applies.

You still have to shut down and lockout and tag equipment according to LOTO standards, even if maintaining the equipment does not require disassembling the machine or its components.

For the record, servicing and maintenance includes: installing, setting up, inspecting, adjusting, repairing, replacing, constructing, modifying, maintaining or servicing machines or equipment. These activities include lubrication, cleaning or unjamming , making adjustments or tool changes, if they expose employees to unexpected release of hazardous energy. Setting up, includes preparing a machine to perform its normal production.

The only exception is minor servicing that must be done while the machine is running, but it must be routine, repetitive and integral to the machine’s operation and there must be acceptable alternative protection.

Some examples include remote oilers, specifically designed tools, remote devices (oilers), interlocked barrier guards, local disconnects, or exclusive control switches for the servicing employee.

2. Energy Control Program

Be sure to have and carry out a comprehensive energy control plan. This includes specific energy control procedures and control circuitry prohibition; periodic inspections, training and retraining.

The procedures must provide the authorized employee specific written instructions on how to remove the potential for unexpected start up or hazardous energy release.

The procedures need to:

• Identify the type and amount of hazardous energy and how the employees will protect themselves.
• Identify the machines and equipment the procedures are to be used on.
• Include steps for placing, removing and transferring lockout/tagout devices.

Also include periodic inspections, at least annually, to ensure the procedures are followed and provide effective protection.

The program also must show that effective training is provided to authorized, affected and other employees, so all employees have the necessary knowledge and skills for the safe application, use and removal of energy controls.

3. Group Lockout/Tagout

When maintenance requires a group of employees, the LOTO standard has specific requirements for procedures and work authorization permits.

A single authorized employee must assume the responsibility for controlling hazardous energy for everybody. This means, the authorized employee must:

• Implement the energy control procedures
• Coordinate the operation
• Ensure all steps are properly completed

All employees must be familiar with the with hazardous energy, and add their own lockout or tagout device to the group device before starting work. The responsible employee must not remove the group device until each employee removes their personal device.

A Work Authorization Permit is a way to comply with the LOTO provisions if included in the written procedures. A permit is completed before any job and identifies the equipment to be serviced, types of hazardous energy,

4. Multiple Energy Sources and equipment

Your program must have a plan for maintenance involving more than one energy source and machines or equipment.

Plan for machines that have more than one type of hazardous energy that must be dissipated or restrained and locked/tagged out, such as: mechanical, hydraulic, pneumatic, chemical, or thermal.

Create energy control procedures for all interconnected machines if the maintenance employee is exposed to hazardous energy release from them.

Top 10 OSHA Violations Examined

Check with us every Wednesday for the rest of the year as we understand the Top 10 OSHA Violations for 2013. Next week’s topic is Electrical General.

1. Fall Protection (1926.501) – October 23

2. Hazard Communication (1910.1200) – October 30

3. Scaffolding (1926.451) – November 6

4. Respiratory Protection (1910.134) – November 13

5. Electrical, Wiring (1910.305) – November 20

6. Powered Industrial Trucks (1910.178) – November 27

7. Ladders (1926.1053) – December 4

8. Lockout / Tagout (1910.147) – December 18

9. Electrical, General (1910.303) – January 8

10. Machine Guarding (1910.212) – January 15