LOCK OUT/ TAG OUT PROGRAM
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1 INTRODUCTION Purpose: This program is established to enhance employee safety by identifying procedures for affixing appropriate lockout or tagout (herein after LOTO) devices to energy isolating devices, and to otherwise disable machines /equipment to prevent the unexpected energization, start-up or release of stored energy. OSHA promulgated the provisions of 29 CFR and 29 CFR intending that compliance with the regulations would reduce the number of employee injuries cause by such unexpected energization, start-up and/or release of stored energy. A copy of the applicable CFR text is available at where you can retrieve by CFR citation. This Lock Out/Tag Out Program ( Program ) has been developed and implemented to promote a safe workplace and in compliance with the applicable statutory scheme. Review: This Program is subject to review and/or revision on an annual basis by the Facility Manager, Company s Safety Officer and General Manager. Additional review and/or revision may be conducted if new equipment and/or hazards are identified before the annual review. Applicability: Refer to Appendix A-1 for a list of equipment/machines at this facility and their energy source locations, covered by this Program. The following is a non-comprehensive list of potential energy sources (including examples) that exist at this facility and are covered by this Program. 1. Electrical (permanent wiring and temporary cables/cords) 2. Pressurized (i.e. air, hydraulic, acetylene, etc) 3. Pressurized Gravity (i.e. raised loaders, tension springs, etc) 4. Inertia (i.e. fly wheels, elevator legs, augers, etc) 5. Heat (i.e. steam, friction, etc) 6. Other unique power source for specific equipment as identified Enforcement: Failure, by any employee, to comply with this Program will result in immediate disciplinary action. Such action will include: 1. First Offense: a. Verbal warning to employee(s) regarding non-compliance with Program b. Written verification of issuance of verbal warning placed in personnel records of employee(s) c. Employee(s) required to attend re-training session focused on particular aspects of Program involved in non-compliance. Certificate of completion/attendance at re-training session placed in personnel file 2. Second Offense: (any non-compliance event following initial verbal warning) a. Formal written warning of non-compliance in personnel file b. Employee(s) required to attend re-training session focused on particular aspects of Program involved in non-compliance. Certificate of completion/attendance at re-training session placed in personnel file c. Written confirmation that employee(s) has been given a copy of this Program and verbally reminded of the Company policy regarding any subsequent Program violations 3. Third Offense: 1
2 a. Written report of violation in personnel file b. Temporary suspension of employee(s) without pay. Length of temporary suspension will be at the discretion of the Facility Manager based on the severity of the violation. Explanation of the length of suspension determined by the Facility Manager will be included in the written violation report. c. Employee(s) must attend re-training (as outlined in 1 st and 2 nd offense provisions) before returning to work 4. Fourth Offense: a. Termination of employment General Requirements: Program as follows: The Company has designated responsibilities for the implementation and execution of this 1. Employer Responsibilities: a. Establish LOTO Program for the Company with annual review of the same b. Provide initial and re-training for all employees as outlined in this Program c. Solicit feedback from employees regarding Program applicability to equipment/machines; review and revise Program as appropriate based on feedback d. Conduct periodic performance reviews of employees to confirm compliance with Program e. Advise outside contractors of Program and confirm outside contractor understands and will comply with Program f. Provide necessary LOTO devices for equipment (i.e. padlocks, tags, hasps, valve lockouts, plug locks, etc. of standard size, shape and color and designed to withstand any environment present at facility) designating the same for LOTO use only g. Provide LOTO center for storage of LOTO devices and training materials, access for authorized personnel only h. Designated LOTO devices for individual authorized employees by placing employees name on LOTO devices i. Purchase only equipment/machinery that has ability to be Locked Out j. Place LOTO placard on all equipment/machines specifying the LOTO procedure appropriate for the equipment/machine 2. Employee Responsibilities: a. Attend mandatory initial and re-training sessions as specified by the Company b. Provide feedback to Company regarding training and Program applicability to equipment/machines in use at facility c. Utilize and comply with Program at all times d. Advise immediate supervisor of any problems encountered with implementation and compliance with Program e. In situations where Tag Out process is used, employees understand that Tags affixed to energy isolation devices MUST NOT be by-passed, ignored or otherwise defeated, as that may lead to severe injury of maintenance/service personnel 2
3 TRAINING PROGRAM Applicability: This training program applies to all Company work operations where employees may be performing work duties on equipment/machinery that must be de-energized. Training: The training, at a minimum, will include discussion of: 1. Summary of the 29 CFR and 29 CFR and this written program 2. Potential hazards associated with energized equipment/machinery at grain handling facilities 3. Identification of equipment/machinery at specific facility which require LOTO procedure compliance 4. LOTO Procedure, including when to use Lock out or Tag out procedures, procedures involving more than one person and returning equipment to normal working state Who Is Trained: Everyone who may reasonably be expected to perform job duties on equipment/machinery requiring LOTO procedure at this facility. In order to accommodate personnel who may not speak English or be proficient in the English language, the Company will: Not allow the employee to begin work activities until the employee has been provided with confined space program training that is translated into the employee s primary language Make arrangements for the employee to be trained on specific confined space entry techniques (both permit required and non-permit required) by a person identified as competent, skilled, and fluent in the employee s primary language Provide information to the employee concerning the availability of instruction on English as a second language When Is Training Conducted: Training will occur when an employee is initially hired, when internal audits of this Program reveals there are deviations or inadequacies in employee knowledge, when new equipment/machinery is installed at this facility and on an annual basis thereafter. Additional refresher training will be required for employees found to be in violation of this Program. INTERNAL AUDITS Purpose: To ensure proper implementation and utilization of this Program. When Conducted: An internal audit will be conducted by the Company General Manager and Safety Officer within the first month after implementation of the Program and on an annual basis thereafter. At least one random (unscheduled) audit will be conducted in the 12 month period between annual reviews, more may occur at the written request of a facility employee. Area of Review: Internal audits will: 1. Confirm Program steps are being followed by all employees as required 2. Employee(s) involved know their responsibilities under this Program 3
4 3. Confirm Program is adequate to provide necessary protection for employees, noting what changes, if any, are needed How Conducted: Internal audits will be conducted by the General Manager, Facility Manager and Safety Officer. The audit will be conducted as follows: 1. All employees included in the audit will be identified and the names will appear on the documentation used to record the date, time and results of the audit. The auditing employees will also be identified on all audit records. A sample of the Audit Checklist can be found in Appendix A-2 of this Program. 2. Audits will be conducted in a one-on-one situation with a follow up meeting with all employees to review general audit results 3. In circumstances where Tag Out efforts are used, the audit will extend to include the employee using Tag Out and all affected employee(s). This is required because the role of affected employee(s) in avoiding accidental or inadvertent activation of equipment/machinery Tagged Out is vital to the overall safety of an operation. 4. Problems/concerns regarding the Program identified during the audits will be noted, reviewed and re-evaluated to determine if revisions to the Program are necessary. 5. Deviations from the Program by audited employees will be noted and addressed with the individual employee to determine if re-training is necessary. Disciplinary action (as previously outlined) may be taken as a result of deviations from the Program discovered during the audit process. CONTRACTOR NOTIFICATION Contractor Notification: Contractors (including any sub-contractors), whose employees may be required to conduct work operations at the Company s facilities or work-sites, including construction sites, will be required to follow all aspects of this Program. In the event the Contractor proposes to use their LOTO Program, the Contractor must provide a copy of their LOTO Program for review by Company representatives before the Contractor s employees being work. The Company will review the Contractor s LOTO Program and written documentation evidencing the training of all Contractor employees on said program. If the Company approves the Contractor s use of their own LOTO Program, a copy of the same will be maintained at the work site throughout the duration of all work performed by the Contractor s employees. LOCK OUT/TAG OUT PROCEDURE General: All equipment shall be de-energized and locked out or tagged out to protect against accidental or inadvertent operation when such operation could cause injury to personnel. DO NOT attempt to operate any switch, valve or other energy isolating device(s) when said device has been locked out or tagged out. The following 4
5 precautions must be taken any time an employee s job duties require maintenance/repair work on energized equipment/machinery. Classification: For the purposes of this Program, Company employees are classified as follows: 1. Affected: Employee whose job requires him/her to operate/use a machine/equipment on which servicing/maintenance is being performed under lock out/tag out or whose job requires him/her to work in an area in which such servicing/maintenance is being performed 2. Authorized: Employee who locks out or tags out machine/equipment in order to perform servicing/maintenance on that machine/equipment. Employees from general maintenance department, setup and tooling personnel and all levels of management from those departments are authorized to implement the LOTO Procedure. 3. Qualified: Employees permitted to work on or near exposed energized parts Lock Out Process: 1. Authorized employee shall complete LOTO Form (sample in Appendix A-3 of this Program) as each step of this process is completed. 2. Authorized employee who will be applying the LOTO device shall notify all affected employees and supervisors that LOTO device is being applied. The notification shall be made before LOTO device is applied. 3. Authorized employee must determine the type(s) and magnitude of energy, hazard of the energy to be controlled, and methods/means to control the energy for any equipment/machine authorized employee proposes to turn off for maintenance/servicing. 4. Shut down equipment/machine by normal stopping procedure (i.e. depress stop button, open toggle switch, etc) 5. Operate any energy isolation device(s) (i.e. valve, switch, etc) so that the equipment/machine is isolated from its energy source(s). NOTE: stores of energy (i.e. hydraulic systems) must be dissipated or restrained by repositioning, blocking, bleeding down or other similar method. 6. Lock out the energy isolating device(s) with lock/tools assigned to individual performing service/maintenance. a. When using a lock with a tag, the authorized employee must clearly display his/her name, date of work and time the equipment/machine is locked out b. Key for the lock being used must only be in the possession of the authorized employee performing the Lock out on the equipment//machine 7. Confirm there are no exposed employees and conduct a check on the lock by attempting to engage the normal operating controls to the equipment/machine. If the machine/equipment is operational, the lock out process has been unsuccessful and authorized employee must start the LOTO process again. 8. Return normal operating controls to OFF or neutral position after confirmation test 9. Perform service/maintenance work as necessary. Upon completion of service/maintenance work, authorized employee: a. Remove all tools from equipment/machine b. Reinstall all machine guards c. Notify all affected employees that LOTO devices are being removed d. Confirm the work area remains clear of other employees 5
6 e. Remove any LOTO device(s) utilized f. Operate energy isolating device(s) to restore energy to the equipment/machine 10. Return completed LOTO Form to supervisor for filing in facility LOTO file. Tag Out Process: Tags serve as a warning device affixed to an energy isolating device but DO NOT provide the physical restraint on an energy isolating device provided by a lock. Tag out process is used ONLY when deenergizing cannot be accomplished by lock out process. 1. Authorized employee shall complete LOTO Form (sample in Appendix A-4 of this Program) as each step of this process is completed. 2. Authorized employee prepares tag for use that is legible and provides information to all affected employees and any other employee whose work operations may be in the area of the authorized employees proposed work. The tag will contain the authorized employees name, date of work and time the equipment/machine is subject to service/maintenance. 3. Tags must be affixed to the energy isolating device by means and materials appropriate to the environmental conditions encountered in the workplace. The means of attachment must be secure to prevent inadvertent or accidental detachment prior to the completion of the service/maintenance. 4. Tags may be removed ONLY by the authorized employee who affixed it to the energy isolating device. 5. Proceed with service/maintenance as necessary. Upon completion of service/maintenance work, authorized employee: a. Remove all tools from equipment/machine b. Reinstall all machine guards c. Notify all affected employees that tag(s) are being removed d. Remove any tag(s) utilized 6. Return completed LOTO Form to supervisor for filing in facility LOTO file. LOTO Involving Multiple Employees: 1. If more than one individual is required to lockout or tagout equipment, each authorized employee shall place his/her own personal lockout device or tagout device on the energy isolating device(s). 2. When an energy isolating device cannot accept multiple locks or tags, a multiple lockout or tagout device (hasp) may be used. 3. If lockout is used, a single lock may be used in a lockout box or cabinet which allows the use of multiple locks to secure it. Each authorized employee will then use his/her lockout protection and only that person will remove his/her lock from the box or cabinet. 4. The authorized supervisor and/or his authorized designee will be the coordinator of the procedure to ensure continuity of the protection level. 5. If more than one crew is assigned to lock out/tag out a machine or piece of equipment, the authorized supervisor or his/her designate must establish separate coordinators for each crew to ensure compliance with the procedure. The multiple coordinators will report to the overall coordinator, which will be the supervisor or his/her designee. Removal of LOTO Devices: Generally LOTO device(s) are to be removed ONLY by the authorized employee who initially applied the LOTO device. However, the Company recognizes that removal of the LOTO device(s) by someone other than the initial authorized employee may be necessary in the event the initial authorized employee is unavailable or an emergency situation arises which require removal of the LOTO device(s). The Company requires 6
7 that the alternate employee proposing to remove the LOTO device(s) must complete the form found in Appendix A- 4 to this Program. The alternate employee must complete the form by initialing each step as taken and signing the completed form. The completed form must be maintained in the facility LOTO file. Miscellaneous: 1. Shift/Personnel Changes: The authorized employee originating the LOTO procedure or the coordinator of a group LOTO procedure will be responsible for the orderly transfer of LOTO device(s) between off-going and on-coming employees to minimize exposures to hazards from the unexpected re-energization of equipment/machinery subject to service/maintenance. 2. Exception to LOTO: Minor tool changes and adjustments or other minor servicing activities which take place during normal production operations are not covered under this Program if they are routine, repetitive and integral to the use of the equipment for production. However, the adjustments or changes being performed must be accompanied with alternative safety measures which provide effective safety protection. HOWEVER, if any form of protective device/guard is removed or employee(s) are exposed to a safety hazard during equipment operation, then this Program is applicable. APPENDICIES Appendix: Attached for reference and enhanced understanding of this Program, are the following: A-1: A-2: A-3: A-4: A-5: Facility Equipment/Machines Energy Source Location Document Sample Audit Checklist Sample LOTO Form LOTO Device Removal By Other Than Initiating Employee Employee Classification 7
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