#OSHALockoutTagout

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OSHA Lockout Tagout Standard: Application of Control 1910.147(d)

The established procedures for the application of energy control (the lockout or tagout procedures) covers the following elements and actions as mentioned above. Preparation of Shutdown: Before an authorized employee turns off the machine, he must have knowledge regarding the types, magnitude, hazards, and the means to control the energy. The first step is intended to notify all the affected employees regarding the Lockout and allow the employees to get ready for the shutdown, and plan ahead to perform safely.

In complex or group Lockout Tagout situations, all involved personnel should be made aware of their respective roles and assignments. Machine or Equipment shutdown: To place the machine in a state that it will let employees work on it safely, it must be turned off or shutdown using established procedures. An orderly shutdown must be used to avoid any increased or additional hazards to employees as result of shut down. Machine isolation: All the isolating devices such as isolators, valves, etc. that are needed to control the energy of the machines, must be physically located and operated so that the machine is isolated from its energy sources. Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

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OSHA Standard 29 CFR 1910.147 - Definition of Hot Tap and & Normal Production Operations

Hot Tap:

As discussed in our previous post, OSHA standard 29 CFR 1910.147(a)(2) does not apply to Hot Tap and Normal Production Operations.

Hot tapping, or pressure tapping, is the method of making a connection to the existing piping or pressure vessels without interrupting the servicing for air, gas, water, steam, and petrochemical distribution systems. This means that a pipe can continue to be in operation while maintenance or modifications are being done to it. Only if the employer demonstrates that

·   continuity of service is essential

·  shutdown of the system is impractical

·   documented procedures are followed, and special equipment is used which will provide proven effective protection for employees.

Normal Production Operation:

Certain tasks such as minor and repetitive adjustments are considered normal production operations when they are integral to the use of the equipment, and when they do not increase the risk of injury to employees.

So, OSHA Standard, 29 CFR 1910.147 (a)(2) does not apply to Hot tap and Normal Production Operations only when the employees working on it are considered to be SAFE.

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

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OSHA Lockout Tagout Standard: Application of Control

Under section (a)(3)(i) of the Lockout Tagout standard 1910.147, the employers are required to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to Energy Isolating Devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees.

This section (d) of the Lockout Tagout standard, highlights the elements of the application of control of the established procedures.

The procedure shall cover the following elements and actions and it shall be done in the sequence mentioned below:

• 1910.147(d)(1): Preparation for shutdown.

• 1910.147(d)(2): Machine or equipment shutdown.

• 1910.147(d)(3): Machine or equipment isolation.

• 1910.147(d)(4): Lockout or tagout device application.

• 1910.147(d)(5): Stored energy.

• 1910.147(d)(6): Verification of isolation.

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

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Lockout Tagout - Energy Isolation and Notification of Employee

Section (c) states that the process of Lockout Tagout shall be performed only by the authorized employees who are servicing. This is so because, an authorised employee is especially trained for the particular isolation, which any other employee might not be able to perform efficiently.

Lockout Tagout requires technical understanding, which cannot be done by any unskilled professional. Therefore, an authorised employee is assigned by the supervisor.

Notification of Affected Employees.

Lack of information regarding the status of equipment could endanger the employees who re-energize, operate or work around the machines. Whenever LOTO control might directly affect another employee’s work activities, paragraph (c) (9) requires the employer or authorized employee to notify the affected employees prior to applying, and after removing the Lockout Tagout device.

Such notification informs affected employees of the impending interruption of the normal production operation and reinforces the importance of the restrictions imposed.

After removing a LOTO device, notifying employees, alerts them that the equipment is capable of being started-up. Else, employees might mistakenly believe that a system is safe to continue working around the machine, leading to heinous accidents.

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

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OSHA Lockout Tagout Standard 1910.147(c) - Employee Retraining

While the employer is required to provide effective training for all employees covered by the LOTO standard, under section (c)(7)(iii) Retraining must be provided to all the authorized as well as affected employees depending upon the circumstances mentioned above.

There are three types of employees which must receive Training & Retraining: authorized, affected, and other. The amount and type of training/retraining that each employee receives is based upon the relationship of that employee's job to the machine and upon the degree of knowledge relevant to hazardous energies.

In addition, retraining must be conducted if an inspection reveals a lack of understanding of LOTO procedures by the employees. This is called Additional Retraining.

Whenever a periodic inspection discloses any deviations or inadequacies in the employees' understanding, additional retraining becomes mandatory.

Under section (c)(7)(iv) Employers are required to certify that effective training and retraining has been provided to all employees covered by the standard. The certification must contain each employee's name and dates of training.

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

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𝐋𝐨𝐜𝐤𝐨𝐮𝐭 𝐓𝐚𝐠𝐨𝐮𝐭 - 𝐓𝐫𝐚𝐢𝐧𝐢𝐧𝐠 𝐚𝐧𝐝 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧 (Part D, E and F)

𝐏𝐚𝐫𝐭 𝐃 specifies,

Tags must be made of materials capable enough of withstanding the environment to which they are exposed for the maximum period of time.

This also means that, exposure to weather conditions or wet and damp locations should not cause the tag to deteriorate.

𝐏𝐚𝐫𝐭 𝐄 further elaborates -

These Lockout Tags although play a very important part in providing safety to the worker applying the safety device, but they might induce false sense of security to the plant worker, if used alone.

Incidences occur where, due to bad environmental condition or physical dismantling, LOTO Tag got removed during servicing, lead to mishaps.

Therefore, Lockout tags must always be used along with LOTO Locks if the machine or equipment in use is capable of being Locked out.

𝐏𝐚𝐫𝐭 𝐅 says,

It is necessary that these Tags must be securely attached to the energy isolating devices so that they cannot be inadvertently detached.

They are non-reusable, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds.

Workers on the site must be specified and trained about these limitations of Tags.

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

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Lockout Tagout - Training and Communication

Although Tags have a significant importance in the LOTO procedure, but when used alone, they have certain limitations, and employees should be trained in the limitations of tags when applied alone. Part A specifies, Tags are warning devices that are affixed to energy isolating devices; which means they do not act as physical restraint on those devices, unlike a lock. When a Lock is applied to an energy isolation device, it acts as a physical barrier that blocks the operation of the machine until the authorized employee removes it. Whereas, Tags applied along with the Lock acts only as a cautionary instruction. They might get dismantled, eroded, ignored, bypassed or defeated, if used alone. Part B says, for the placement of Lockout Tags, an authorized employee is always assigned by the supervisor as per the procedure. This person is a trained employee who knows what devices to be used, how and where to be used effectively to block the flow of hazardous energies. Since, these industrial tags are made of high performance, durable materials that can withstand harsh environments - both indoors and outdoors; they cannot be bypassed or defeated unless intentional. Part C says, Tags must be legible and understandable by all authorized, affected, and other employees who are involved. OSHA requires that the major message printed on the tag “warn against hazardous condition of the equipment is re-energized.” Five examples of acceptable warnings are provided, including Do Not Start. Do Not Open. Do Not Close. Do Not Energize. Do Not Operate. In all cases, employees must know and understand the meaning of the Tag. For more details about Tag limitations, visit -  https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

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Lockout Tagout - Training and Communication

Training is one of the most important steps in the process of Lockout Tagout, needed to provide employees with knowledge, skills and motivation to effectively implement a successful Lockout Tagout program. OSHA instructs in Standard 1910.147 with respect to employees training states that - Training must ensure that the purpose and function of the energy control program are understood by employees.

As a basic requirement, all employees should be trained in the basis of Lockout Tagout. Through this training, all employees should understand the purpose, function, and restrictions of the Energy Control Program. The training needed by each employee should be provided initially upon assignment. For the purpose of the standard, three types of employees that require training are recognized - Authorized, Affected, and Other. Under section (c)(7)(i)(A) Each authorized employee must be trained enough to recognize the applicable Hazardous Energy sources, the type & magnitude of the energy available in the workplace, the methods & means necessary for energy isolation & control. Under section (c)(7)(i)(B) Affected employees must be instructed in the purpose and use of the energy control procedure. Employees who exclusively perform functions related to normal production operations and who perform servicing and/or maintenance under the protection of normal machine safeguarding need only be trained as affected employees even if tagout procedures are used.

Under section (c)(7(i)(C) This group consists of anyone else who works in an area where LOTO procedures are used. All of these employees must be instructed about the procedure, and trained not to start locked or tagged equipment, and not to remove or ignore lockout tagout devices. Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-standard/

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OSHA Lockout Tagout Standard - 1910.147(c)(6) Periodic inspection

To ensure that the energy control procedures in place are adequate and being properly and consistently applied, a Lockout Tagout program must be reviewed/inspected periodically and revised if needed. Section (c)(6) of the OSHA Standard sets forth specific requirements for conducting the periodic inspection.

The periodic inspection provisions of the standard 1910.147(c)(6)(i) require that energy control program be reviewed at least annually to ensure compliance. The intent of this requirement is to ensure that energy control program is updated, accessible, and being implemented properly, and that the employees remain familiar with their responsibilities under those procedures. The periodic inspection also serves as an essential check to verify the continued proficiency of the employees in the safe application, use, and removal of the energy controls.

Under section (c)(6)(i)(B) The periodic inspection must be designed to correct any deviations and inadequacies observed, and the employer must certify that the periodic inspections have been performed.

Further, under Section (c)(6)(i)(C) of the standard requires that the inspector reviews the responsibilities of each authorized employee under the procedure with that employee.

Under Section(c)(6)(i)(D) the standard requires that when tagout alone is used, both authorized and affected employees must review the use of the tagout system as part of the annual inspection. This additional review is necessary because of the shortcomings of the tagout system. Tags can be removed or bypassed, and provide limited protection when compared to locks. To ensure proper implementation of Tagout, it is also important to periodically review responsibilities with affected employees and remind them of the restrictions imposed on them under the program. When Tagout alone is used, the annual inspection must also include a review on the limitation of tags with each affected and authorized employee.

Certifying the Inspection - 1910.147(c)(6)(ii)

Under the Standard 1910.147, the employer shall certify that the periodic inspections have been performed. In addition to the equipment, date of the inspection, name of the inspector, the employees included in the inspection and the person performing the inspection must also be documented. This document is intended to ensure that the involved employees have had the opportunity to review their responsibilities and demonstrate their performance under the procedure.

The inspection must be able to determine:

·  Whether the steps in the energy control procedure are being followed

· Whether the employees involved know their responsibilities under the procedure

· Whether the procedure is adequate to provide the necessary protection, and what changes, if any, are needed.

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

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OSHA Lockout Tagout Standard - Lockout Tagout devices must be Standardized & Identifiable

Under section (B) of (c)(5)(ii) of the OSHA Standard 1910.147, requires that Lockout Tagout Devices must be standardized in either colour, shape, size, print or format. The requirement of the standardized devices is meant to ensure that they are readily identifiable, unique, and distinguished from other similar devices found in the workplace. The intent of these provisions is to elevate the importance of Lockout Tagout devices and ensure that all the employees understand their distinct and exclusive purpose - to protect services & maintenance employees from accidental start-up or the release of stored energy. Section (c)(5)(ii)(D) of the standard requires that Lockout Tagout devices identify the employees who apply them. This requirement adds a degree of accountability to the LOTO program. Once the involved employee is identified, he/she can be located when needed. This identification is also essential as it enables the employer to quickly determine the identity of the employee who forgot to remove his lockout Tagout device. Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

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OSHA Lockout Tagout 1910.147(c)(5): Lockout Tagout devices must be Substantial

Lockout Devices typically Locks, hold energy Isolation Devices in a safe, off or neutral position. They provide protection by preventing machines or equipment from becoming energized because they are positive restraints, consequently. They should be substantial enough to prevent their removal by an authorized person without the use of excessive force or special techniques.

Tags and their means of attachment constructed must be substantial enough to minimize the potential for them to be disconnected, lost or accidentally removed. Tag attachment means are further required to be attachable by hand, and equivalent in strength to a one-piece non-releasable, self-locking cable tie. To meet these requirements, environment tolerant nylon cable tie that has an unlocking strength of about 50 pounds is used for attaching tags.

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

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OSHA Lockout Tagout Standard - 1910.147(c)(5)(ii)(A) - Protective Material and Hardware - Durability

According to OSHA Standard 1910.147(c)(5)(ii)(A) - The Lockout Tagout devices must be DURABLE. The durability requirements are intended to ensure that the Lockout Tagout devices will not fail to perform their intended job. The LOTO Devices must be durable enough to resist the harsh environmental conditions - chemicals, abrasion and temperatures, to which they are exposed to for the expected period of time.

Tags and their means of attachment must be constructed and printed, so that the exposure to weather or other environmental conditions does not cause them to become unserviceable or the message on the Tag to become illegible. Using laminated Tags with reinforcing eyelets is generally adequate for the vast majority of work environment.

Tags so constructed, must also be durable enough to withstand the corrosive environment, especially the areas where acid and alkali chemicals are handled and stored.

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

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OSHA Lockout Tagout 1910.147(c): Protective Materials and Hardware

To perform service or maintenance safely and effectively under Lockout Tagout, employees must be provided with protective equipment, hardware and appliances for isolating, securing, or blocking of machines & equipment from their energy sources. Under paragraph (c)(5) of the OSHA Standard, it is the employers’ responsibility to provide necessary devices. Protective material and hardware that may be needed include locks, tags, cable ties, chains, breakers and valve lockouts, wedges, blocks, blinds, pins, fasteners and other hardware.

When launching a lockout tagout program, a survey of the workplace is needed, not only to identify the machines, equipment and processes that are covered by the program, but also to become familiar with the configuration of the equipment. When ordering the necessary hardware, the employer must also ensure that the hardware meets specific requirements for design & construction.

Under paragraph (c)(5)(ii) it states that the Lockout & Tagout devices should be singularly identified. Which means- the best suitable device should be placed on the isolating point and should not be used for any other purpose apart from Lockout Tagout on machines & equipment.

Section A-D of paragraph (c)(5)(ii) specifies certain requirements of lockout Tagout devices, i.e. The device must be durable, Standardized, Substantial and Identifiable.

In paragraph 1910.147(c)(5)(iii), OSHA requires that the major message printed on the tag “warn against hazardous condition of the equipment is re-energized. Five examples of acceptable warnings are provided, including Do Not Start. Do Not Open. Do Not Close. Do Not Energize. Do Not Operate. In all cases, employees must know and understand the meaning of the Tag.

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

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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 Lockout Tagout: Full Employee Protection

OSHAs Lockout Tagout Standard does not prescribe the specifics of the energy control measures to be employed. Although, the standard lays down general procedures to be achieved, giving the employers flexibility in choosing the control procedures to be implemented, it focuses on achieving full employee protection.

Full Employee Protection:

As per OSHA Standard 1910.147(c)(3) - A lockout device should always be used when the machine’s energy isolating devices are capable of being locked out. But, there might be situations when, an isolating device is not capable of being locked out, a Tagout device is used alone in place of a Lockout device {1910.147(c)(3)(i)}.

In such a situation, 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.

The employer must demonstrate full compliance with all Tagout related provisions of this standard. Additional protective 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 probability of inadvertent energization are needed to demonstrate that full employee protection has been achieved. Along with this, if an energy isolation device is not capable of being locked out, it must be redesigned or modified to accept the lock whenever major replacement, repair, renovation or modification of the machine is performed. The main motive is to achieve Full Employee Protection always. Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-standard/