#EnergyControlProcedure

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OSHA 1910.147(c)(4)(i) - Exceptions to Energy Control Procedures

Energy Control Procedures or Machine Specific Procedures need to be developed, documented & utilized always for full employee protection. If the total employee protection is obtained without ECP, then the need for developing ECP can be exempted. But all the essential elements required for complete safety of the employees have to be fulfilled.

The exemption is mostly for the simple equipment, when the Lockout device is under the exclusive control of the authorized employee, there is no potential for inadvertent release of stored or residual energy, and a single lockout device can achieve a locked-out condition. But in industries, even the complicated machines do not have the ECP. Many times when there are replicas of the same equipment, then the generic or common ECPs are used which leads to a lot of confusion & adequate energy control is not achieved, resulting in serious accidents.

So, ECPs are required for the isolation of hazardous energies & absence of ECP is the most common violation as per OSHA Standard 29 CFR 1910.147.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-explained/

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OSHA 1910.147(c)(4) Energy Control Procedure

Most of the OSHA Violations are due to the unavailability of Energy Control Procedures (ECP) or Machine Specific Procedures (MSP) in organisations. Companies buy Local products, just to become LOTO compliant, but they do not know the correct procedure for safe isolation and control of Hazardous energies. Successful implementation of Energy Control Program requires an understanding and awareness of Hazardous energy types and magnitude, the methods, techniques, and devices used to control that energy.

To provide guidance to employees for putting the program into practice, written Energy Control Procedures should be developed. These procedures must define the purpose, scope, and application of the program, deploy the responsibilities of the managers, supervisors, and employees for implementing a systematic Lockout Tagout program.

A written Energy Control procedures (ECP) / Machine Specific procedures (MSP) needs to be developed, documented as it clearly and specifically outlines the steps to be followed, techniques to be used, and measures to be applied for the control of potentially Hazardous Energy.

This includes specific steps to shut down, isolate, block, secure, place, and remove lockout or tagout devices, and to determine the effectiveness of those devices by following verification steps.

The written ECP/MSP must have pictorial representation for isolation, installed images of LOTO devices that specifies procedural steps for the placement, removal and transfer of Lockout Devices or tagout devices.

Lack of compliance can lead to serious disciplinary actions. Industries need to mention the consequences in case of non-compliance of Lockout Tagout due to any reason, whatsoever.

Periodic inspections are mandatory to help ensure that the energy control procedures and the requirements of the standard are being followed.

Services of LOTO can be taken for developing ECPs/MSPs as they have vast industrial knowledge to prescribe the proper steps for the safe isolation by the correct use of Lockout Tagout.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

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OSHA 1910.147 (c)(2) General - Lockout Tagout

The OSHA Standard, 1910.147 (c) set forth nine general principles which provide the framework for ensuring the safety of personnel who maintain the machines.

OSHA Standard 1910.147(c)(2) emphasizes on the importance of Full Employee protection by Lockout Tagout.

Generally, the isolation devices should be capable of being locked out in majority of circumstances. But, there can be incidences where a Tagout device is used instead. A Tagout device, without a Lockout, may be used only when energy isolating device, is not capable of being locked out, or when the employer demonstrates that use of the tagout system alone, is substantial enough to be used in place, where the Lockout device is not applicable. It must provide a level of safety equivalent to that obtained by using a Lockout device, and the Tagout device must be attached at the same location, where the Lockout device would have been attached.

In such a situation, it solely becomes the responsibility of the employer to provide ‘full employee protection.’

After January 2, 1990 according to the standard 1910.147 (c)(2)(iii), it has become mandatory for the manufacturers, that in case of modification of machines and equipments, whenever replacement, major repair or installation of new machines are done, the energy isolating devices for such machines or equipment shall be designed to accept a lockout device.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-explained/

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OSHA Lockout Tagout Standard 1910.147(c)(1) - Energy Control Program

LOTO is intended to provide effective safety in the modern industrial workplace. It saves lives by protecting workers from hazardous energy, and it reduces downtime by streamlining and standardizing work processes. For successful implementation of Lockout Tagout in an industry, it is important to have awareness about LOTO and a well-developed LOTO System. Lack of knowledge and absence of LOTO system, leads to uncalled eventualities. Even with the re-occurrence of repeated incidences, the workers and the management are not sure that it is due to the absence of proper LOTO System in place.

The employer is to establish an Energy Control Program - comprising of the energy control procedures, employee training and periodic inspections, all of which help to ensure that the machine and equipment are properly isolated from their energy sources, and rendered inoperative prior to any servicing and maintenance.

A well-defined energy control policy and procedure helps in planned and systematic working of the machines and equipment; Employee training is needed to provide employees with knowledge, skills and motivation to effectively implement a successful Lockout Tagout Program; Audits & periodic inspections help companies insure that, they have the up-to-date & accurate devices and procedures that allow employees of the companies to safely de-energize the equipment.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-explained/