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How to Avoid a $119,500 Fine

Posted by Admin on 11/3/2014 to lockout tagout

Does your company ignore lockout/tagout procedures?

In march of 2012, OSHA slapped a $119,500 fine on a company in Presque Isle, Maine following the death of one of their workers. The worker died when he became caught in moving parts of a machine known as a stacker, which activated while he was inside the machine performing maintenance. OSHA's inspection found that the machine had not been turned off and its power source had not been locked out to prevent its unintended startup, as required under OSHA's hazardous energy control, or lockout/tagout standard.

"This is exactly the type of incident the standard (29 CFR 1910.147) is intended to prevent. Had proper lockout/tagout procedures been used, this needless death could have been avoided," said the OSHA area director.  "What's especially disturbing is that this employer well knows the requirements to power down and lock out machinery, yet ignored them."

As we know, the standard covers the servicing and maintenance of machines and equipment, and associated activities.  Its purpose is to protect employees from injury and possible death due to unexpected/unintended motion, energization, start‑up, or release of stored energy from machines, equipment, or processes.  It establishes minimum performance requirements for the control of such hazardous energy.

Energy sources include electrical, pneumatic, hydraulic, mechanical, thermal and chemical.  There may also be stored energy, residual energy that may remain once the primary energy source is shut down.

OSHA requires the employer to plan for the control of energy during servicing and/or maintenance of machines and equipment by doing the following:
  • Survey the entire facility to determine locations of all hazardous energy sources;
  • Develop, document and utilize lockout/tagout procedures;
  • Provide employees appropriate training;
  • Provide, at no cost to employees, equipment required by the lockout/tagout procedures;
  • Continuing competency through training; and
  • Include outside contractors, if any.
Before starting a service and/or maintenance task, the hazardous energy sources must be isolated, and locked or tagged out. Typical tasks requiring lockout/tagout procedures include:
  • A task requiring an employee to place any part of their body into an area on a machine’s point of operation or where an associated danger zone exists during a machine’s operating cycle;
  • Cleaning, repairing, and maintaining machinery with moving parts;
  • Clearing jammed mechanisms;
  • Removing or bypassing a guard or other safety device; and
  • Repairing electrical and other energized sources.
The standard applies to general industry employers and does not apply to:
  • Construction, agriculture and maritime employment;
  • Installations under the exclusive control of electrical utilities for the purpose of power generation, transmission and distribution, including related equipment for communication or metering;
  • Exposure to electrical hazards from work on, near, or with conductors or equipment in electrical utilization installations; and
  • Oil and gas well drilling and servicing.
When a machine specific documented procedure is required, it must include the following actions and elements which should be accomplished in the order listed below and encompass the lockout/tagout program as a whole.

      1.   Preparation for shutdown

All authorized employees need to know the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy before the employee turns off a machine or equipment.

       2.   Notify all affected employees

The authorized employee turning off the power warns affected employees in the work area that power will be shut off, the reason for the shut-down, and that the equipment will be locked/tagged out.

       3.   Machine or equipment shutdown

Procedures must be established for turning off or shutting down each piece of equipment.  An orderly shutdown must be utilized to avoid additional or increased hazards to employees as a result of the equipment stoppage.  When appropriate, a “DO NOT OPERATE” tag shall be affixed to the OFF switch.

       4.   Machine or equipment isolation


Physically locate all energy isolating devices that are needed to control the energy of the machine or equipment.  Isolate the machine or equipment from the energy sources.

       5.   Lockout or tagout device application


The authorized employee places locks or tags in the appropriate energy isolating location.  A lockout device is defined as a device, such as a key lock, that utilizes a positive means or holds an energy isolating device in a safe position and prevents the energizing of a machine or equipment. The equipment being controlled may not be operated until the tagout device is removed.

Remember:

  • Only authorized employees shall place the lockout or tagout device on each energy isolating device;
  • Lockout devices need to be affixed properly so that it will hold the energy isolating devices in a SAFE or OFF position;
  • Tagout devices, when used, must be placed to clearly indicate that operation or movement of energy isolating device from the SAFE or OFF position is not allowed.

       6.   Release of stored energy

After lockout devices have been placed on the equipment, all stored electrical, gravitational, mechanical, and/or thermal energy must be disconnected and drained to a zero energy state or otherwise made safe by blocking or repositioning of equipment.  This can be accomplished by:
  • Release of pressurized lines such as hydraulic, air, steam, gas and water;
  • Release of spring-loaded equipment;
  • Blocking mechanical equipment with moving, rotating, or elevated parts.
       7.   Proof of isolation

Before starting work on a machine or equipment that has been locked out or tagged out, the authorized employee needs to show that machine or equipment has been isolated or de-energized.  This is generally accomplished by first establishing that no personnel are exposed and then turning the machine switch to the ON position using the normal operating controls.

Verification of isolation must be continued if there is a chance of the re‑accumulation of stored energy during the service/maintenance activity.

       8.   Use of Tagout Systems

A tagout system may be utilized by an employer when an energy isolating device is not capable of being locked out.

When the energy isolating device is capable of being locked out, the employer must use lockout unless it can be demonstrated that the utilization of a tagout system will provide full employee protection.

After January 2, 1990, whenever replacement, major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, it must be capable of accepting a lockout device.

Whenever tagout systems are used, all other procedures consistent with the lockout program must be followed.  Additional control measures must also be taken to reinforce the tagout system.

Lockout is a sure means of ensuring de-energization of equipment.  Therefore, when a tagout program is used for equipment capable of being locked out, an employer must demonstrate the following:

  • Tagout program will provide a level of safety equivalent to that obtained by using a lockout program;
  • Full compliance with all tagout-related provisions of this standard together with such additional elements as are necessary to provide the equivalent safety available from the use of a lockout device;
  • Implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.
       Tags must meet the following minimum guidelines:

  • Tags must be legible and understandable by all affected and authorized employees;
  • Tags must contain warnings against energizing the equipment, such as DO NOT START, DO NOT OPEN, DO NOT CLOSE, DO NOT ENERGIZE, or DO NOT OPERATE;
  • Tags must be able to indicate the identity of the employee applying the device.
Tags attached to energy isolating devices should be removed only by the person originally attaching them.  Removal by anyone else must follow employer approved guidelines.

Tags must be attached to energy isolating devices securely enough that they cannot be accidently removed and must be in plain view and at the same location as the energy isolating device.  Tags cannot be bypassed, ignored or otherwise defeated.

When tagout systems are used, employees must be trained in the following limitations of tags:

  • Tags are only warning devices placed on energy isolating devices, and do not provide physical restraint on those devices that is provided by a lock;
  • Once a tag is attached to an energy isolating means, it is not to be removed without permission from the authorized person responsible for it;
  • A tag should also never be bypassed, ignored, or otherwise defeated;
  • Tags must be legible and easily understood by all authorized employees, affected employees, and all other employees whose work operations are in or near the area;
  • Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace.
9.    Employee Training

The employer’s training program must cover, at a minimum, the following three areas: energy control program, elements of energy control procedures relevant to employee duties, and applicable requirements of the standard.

The lockout/tagout requirements include three different levels of training requirements which depend on the duties assigned to the employee.  Employees are categorized as Authorized, Affected and Other.

Management shall certify that employee training/retraining has been accomplished and is being kept up to date. Certification shall include written documentation containing the employee’s name, category status (authorized, affected, other), and dates of training as well as a signed statement by the supervisor signifying that the training has been conducted.

Nevada Technical offers a wide range of training materials to help meet this regulatory burden, including a line of lock-out tag-out training videos.

a. Authorized Employees

Authorized employees are those who have received proper training and will be issued and apply lockout/tagout devices.  An affected employee becomes an authorized employee when duties include performing servicing or maintenance while exposed to potentially hazardous energy. Training for authorized employees shall include:

  • Recognition of locations, types and magnitudes of potential hazardous energy sources in the work area;
  • Proper lockout/tagout procedures;
  • Proper use of lockout/tagout devices (and any related equipment) used by the employer;
  • Lockout or tagout device removal.
b. Affected Employees

Affected employees need instruction in the purpose and use of the energy control procedures because they must work in the area where equipment is being serviced or maintained under lockout or tagout.  The training shall include:

  • Purpose of the energy control procedures;
  • Use of the lockout/tagout procedures;
  • Prohibition on tampering with lockout/tagout equipment.
c. Other Employees

Other employees must be instructed about the employer’s lockout/tagout  procedures.  These employees must also be aware that attempts to restart or re‑energize machines or equipment which are locked out or tagged out are not allowed.

 10. Shift Changes

The continuity of machine safeguarding during shift or personnel changes or during long intervals of time between when work will be accomplished through the use of an equipment lock.  Personnel changing shifts will install an equipment lock to the lockout adapter prior to removing their personal safety lock unless the equipment is ready to go back into service.  A tag indicating the status of the machine/equipment will be attached to the equipment lock.

Equipment locks will be applied and removed by supervisory/ management personnel.

  11. Lock Removal

Each lockout lock shall be removed from each energy isolating device by the authorized employee who applied the device except for conditions specified in emergency lock removal.  A lockout must never be broken (lock removed) by anyone other than the employee who performed that lockout.

12. Emergency Lock Removal

When an authorized employee is not available to remove their lock, the supervisor and operations managers of that employee have the authority to request the removal of a lock in the absence of the employee.  In those cases when a supervisor exercises that authority, the following procedure must be followed:

a.    The supervisor should contact an authorized person and request assistance in this procedure.

b.    The supervisor and an authorized person must attempt to contact (at least verbally) the employee to whom the lock belongs and determine if the employee is on the premises.

c.    If the employee is on the premises, he/she alone has the authority to determine whether the lock can be removed based on the guidelines of the lockout procedure.

d.    If the employee is not on the premises, the supervisor or an authorized person will make a reasonable effort to contact the employee and will ask the employee whether the work is complete and the equipment is ready to be activated.  The employee will be advised that his/her lock will be removed.

e.     If the employee advises that the equipment is ready to be activated, the supervisor shall inspect the work area to verify that there is no danger in re-energizing the equipment, remove the lock, and inform the department management that the equipment is operational.

f.      If contact is not established, the supervisor will inspect the equipment for completeness of work and authorize the removal of the lock.  The employee whose safety lock has been removed will be notified immediately upon return to work by a note being attached to his/her time card requiring that they come to supervisor’s office for safety lock.

g.   If the equipment is ready to be activated, the supervisor will inform  the department management that the equipment is operational.  At this point, the supervisor can authorize removal of the lock.

The person removing the safety lock is responsible for making certain that all requirements for restoring power are followed prior to removing the safety lock.


13. Lockout/Tagout Devices

List the types of lockout devices authorized for use at your facility.  Here are some examples.

 a.   Electrical disconnect or breaker lockout device - the switch lever must be padlocked in the OFF position using a shackle and/or padlock with an identification label.

b.   Valve lockout device - can be locked out by using a padlock, a cable and lock, or a valve handle lockout devices.  The method used is determined by the type of valve

c.   Line Blinds or “Pancakes” - to isolate the time flow of fluid or gases in piping systems.  (To be used in conjunction with pipe breaking procedures.)

e.   Multiple locks (gang hasp) - when more than one person or group has to work on a machine, a lock adapter shall be used.  Each person or group must place a lock on the adapter thus assuring each person a safe and complete lockout.  It is important that during a shift change, locks be left in place until the time that the next crew is present and have placed their locks  in the adapter.

Illustration of a typical lockout/tagout kit:


  • Tags and Locks
  • Self-locking fasteners
  • Chains
  • Wedges
  • And other assorted items

 

 


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