COMPLETE AND EFFECTIVE LOCKOUT / TAGOUT PROGRAMS

Transcription

1 COMPLETE AND EFFECTIVE LOCKOUT / TAGOUT PROGRAMS ARE YOU REALLY COMPLYING WITH OSHA REGULATIONS FOR CONTROL OF HAZARDOUS ENERGY? Prepared by Peter S. Puglionesi, P.E., DEE David C. Baird Joshua Kaplan Copyright 2009 Applied EHS Management, Inc peter.puglionesi@appliedehs.com

2 Table of Contents Introduction... 1 Who Must Comply?... 1 What Does LOTO Apply to?... 2 Are There Exceptions to the LOTO Standard?... 2 What Are The Main Components of a LOTO Program?... 3 Written LOTO Program... 3 Roles of Key LOTO Program Personnel... 4 Written Energy Control Procedures (ECPs)... 4 LOTO Hardware: Locks and Tags... 5 LOTO Training and Communication... 5 LOTO Periodic or Annual Inspections... 6 Improving Safety by Design... 7 OSHA Amputation Initiative: What Should We Expect?... 7 How Do We Achieve LOTO Excellence?... 8 About Applied EHS... 9

3 COMPLETE AND EFFECTIVE LOCKOUT / TAGOUT PROGRAMS ARE YOU REALLY COMPLYING WITH OSHA REGULATIONS FOR CONTROL OF HAZARDOUS ENERGY? Peter S. Puglionesi, P.E., DEE; David C. Baird, III; Joshua Kaplan Applied EHS Management, Inc.; Introduction OSHA initially relied on the General Duty Clause to ensure that employers safeguarded employees from the unintentional release of hazardous energy but the large number of severe injuries and General Duty citations pointed to a need for development of a standard. The OSHA standard for the control of hazardous energy, often called Lockout/Tagout (LOTO), has been in effect since 1990 (29 CFR ). Almost every maintenance shop has a LOTO board with lockout/tagout equipment. Even today, 20 years after the development of the standard, few operations understand or follow the full extent of the requirements. OSHA has implemented new initiatives to reduce injuries caused by failure to control the release of hazardous energy during maintenance and repair. One such initiative, the National Emphasis Program on Amputations (NEP), was instituted to reduce amputations and related fatalities in selected industries. As an executive, plant manager, maintenance supervisor or Health and Safety Coordinator - you should be aware of OSHA s initiatives and, more importantly, understand how to protect your company s most valued asset, your employees. This distills OSHA LOTO regulations and interpretations and provides some clear guidance on understanding and complying with the standard and taking some simple steps to protect your employees from serious injury. Who Must Comply? All employers must comply with the LOTO OSHA standard. Just in case you are wondering, an employer is defined as any person engaged in a Page 1 of 11

4 business affecting commerce and who has an employee. While it does not include the United States, State or any political subdivision of the state U.S. government employees are covered by executive order and state and local government employees are covered in about 25 states by state regulations and programs. What Does LOTO Apply to? The standard applies to the control of hazardous energy during the service and/or maintenance of machines or equipment. The primary focus of LOTO is to ensure machines or equipment are isolated, rendered inoperative and locked out so there is no unexpected startup, release of stored energy that can cause injury. Are There Exceptions to the LOTO Standard? Certain work, where employees are not exposed or equivalent protections are in place, is not covered by the standard. This includes: 1. Work being performed during normal production operations that does not require employees to remove or bypass a guard or safety device. Some examples include minor tool changes, adjustments, and other routine or repetitive activities where there are other means of protection offered (e.g., using special tools that do not endanger fingers or hands during specific tasks). This is sometimes referred to as routine maintenance. 2. Work on cord and plug connected electric equipment where the plug is under the exclusive control of the employee performing the work. Exposure to all hazardous energies must be controlled by unplugging the equipment. Be aware that some equipment with a plug may have other stored energy sources (e.g., electrical, mechanical, hydraulic, pneumatic, chemical, thermal). Examples can include kinetic energy in springs or pneumatic energy (air pressure) still stored in an air compressor. If you cannot control the plug (e.g., large equipment or equipment remaining out of service), plug locking devices may be needed. 3. Pneumatic tools that no longer contain hazardous energy once they are isolated from air energy sources by disconnecting the hoses from the equipment. Page 2 of 10

5 4. Exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations as covered in Subpart S of 29 CFR 1910, Electrical. 5. In certain special situations where hot tap operations are necessary and there are no other practical methods to isolate energy to perform the maintenance or repair task. 6. Construction *, agriculture, and maritime employment. 7. Oil and gas well drilling and servicing. What Are The Main Components of a LOTO Program? The primary focus of LOTO is to ensure machines or equipment are isolated, rendered inoperative and locked out during service and/or maintenance so there is no unexpected startup, release of stored energy that can cause injury. If you are subject to the OSHA requirements, you should understand these components: 1. Written LOTO Program 2. Roles of Management, Authorized and Affected Employees 3. Written Energy Control Procedures (ECPs) 4. LOTO Hardware: Locks and Tags 5. LOTO Training and Communication 6. LOTO Periodic or Annual Inspection Written LOTO Program A Lockout/Tagout energy control written program is required by the regulation. It should include general equipment lockout/tagout instructions, employee responsibilities, a system for developing and using written and specific energy control procedures for each piece of equipment (or type of equipment) having multiple energy sources, acceptable LOTO hardware (e.g., locks and tags), means for training & retraining of employees affected by lockout/tagout activities and those authorized to perform LOTO procedures, process for conducting annual * See the OSHA construction standard 29 CFR 1926 for specific requirements during construction activities. Construction activities in an operating facility however would still require facility employees to be protected and thus LOTO would apply. Page 3 of 10

6 or periodic inspections of LOTO procedures. Whenever a facility uses contractors in a general industry environment (e.g., where your employees may be exposed to hazardous energy), they must also follow a compliant written program. Roles of Key LOTO Program Personnel Management Committed to providing the resources, training and equipment to implement the standard EHS Manager/Supervisor May designate positions to oversee LOTO Compliance and/or supervise group lockouts. Authorized Employee An employee who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. Affected Employee - An employee whose job requires him or her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him or her to work in an area in which such servicing or maintenance is being performed. Written Energy Control Procedures (ECPs) Equipment with multiple energy sources must have a written energy control procedure (ECP) with the steps needed for isolating all energy sources, releasing stored energy and verifying all energies have been isolated or released (e.g., opening drain valves to drain pressure from a pump an verifying liquid drains and stops flowing or grounding stored electrical energy and testing for zero potential prior to beginning work). The procedure must also cover the process of removing locks and tags and placing equipment back in service. Any Authorized Employee who is responsible for applying locks or tags on the equipment must have access to and understand the LOTO ECP. LOTO ECPs can be of various shapes and sizes. They should be prepared in advance for common Preventive Maintenance and may be written as needed for Corrective Maintenance or major overhauls. The key with any LOTO ECP is to have listed the necessary energy isolation and control stored energy steps to prevent employees from being hurt by unexpected energy release or startup. Page 4 of 10

7 LOTO Hardware: Locks and Tags All locks and tags must be clearly identifiable by affected employees, so they need to be standardized (i.e., the same color and type). Tags and tag ties must be sturdy. Other hardware to assist in the lock out of equipment or machines may include lockable valve covers, cables and chains, all designed to secure equipment without a built in locking point. Every lock needs to identify the employee who applied it. This can be accomplished by a tag or issuing locks identifying the employees using them. Where more than one employee will be working on equipment at the same time, every employee must apply a lock. This can be through the use of a multi-lock tree hasp or a lock box containing the keys to primary equipment locks with multiple locking points for every employee to apply their lock when they begin working on the task. Efficiencies like reusable tags and group lockout are a good idea, just be sure the program integrates the basic requirements of every employee identified and protected and that employees understand it. LOTO Training and Communication Employers must certify that they have provided LOTO training to all affected and authorized employees. This includes new employees as well as existing employees that have a change in job assignment, are exposed to a new hazard, or when there is a change in energy control procedures. Periodic retraining may be required if deficiencies are discovered during LOTO Annual or Periodic Inspections (see below). Authorized Employees: Training on the program, ECPs, recognizing types and magnitudes of energy sources, application of locking and tagging devices, safeguarding equipment and machines from hazardous energy sources during shutdowns, releasing stored energy, and properly placing equipment (or machines) back inservice after the LOTO. Affected Employees: Training on the purpose of lockout/tagout, recognizing locks/tags and the prohibition on removing these devices or operating locked/tagged equipment. Page 5 of 10

8 LOTO Periodic or Annual Inspections OSHA requires the employer to perform and certify periodic inspections to ensure employees understand and are correctly following the energy control procedures at least annually. The requirements are vague and employers often don t understand them or document their completion. OSHA clarified its expectations, particularly for those that have many written ECPs, in an OSHA Standard Interpretation (Lock out/tag out periodic inspection requirement - 3/9/04). With a small crew performing primarily single-energy source LOTO, annual inspection is easy. In order to best test their knowledge and following of procedures, observe their work without supervising them. Of course, intervene before they may expose someone to hazardous energy. Any inadequacies or discrepancies identified during the inspection and the corrective action taken should be documented. The results of inspection must be reviewed with all employees who may perform the same or similar LOTO. Retraining may be required if the deviations or inadequacies identified during the inspection are persistent or serious in nature. Where employees generally work individually, there are numerous crews performing LOTO, contractors are sometimes involved or there are many ECPs for different types of equipment, you should have a plan to inspect sufficient LOTOs each year to assess the effectiveness of the program. The frequency and amount of inspections performed depends on the number of different equipment groups (e.g., pumps, air compressors, tanks, HVAC equipment) in your facility, the number of individuals or crews and how often equipment is locked out. Certify that inspection was performed by documenting the equipment, which ECP was used, the date of the inspection, the employees included in the inspection and the person performing the inspection. The person performing the inspection must be an Authorized Employee who is knowledgeable on the equipment being locked-out and on using ECPs but cannot supervise the LOTO being inspected. Page 6 of 10

9 Improving Safety by Design As of January 2, 1990, machines or equipment must be designed to integrate or accept a lockout device whenever major repairs, renovation or modification of a machine or equipment will expose employees to hazardous energy. Current electrical standards call for a local, lockable disconnect that isolates all sources of energy to hard-wired equipment. You may want to consider minor upgrades to old systems to simplify lockout and improve compliance and protections such as installing local lockable disconnects. Ease of lockout should also be a part of any new design of complex systems that may have computerized controls and multiple power feeds. OSHA Amputation Initiative: What Should We Expect? The National Emphasis Program on Amputations, one of many OSHA outreach programs, is designed to reduce amputation injuries and fatalities by improving compliance with machine guarding (29 CFR ), LOTO hazardous energy control (29 CFR ) and other applicable regulations. This program has been in effect since 2002 but was refocused in late 2006 to target workplaces having machinery or equipment that commonly cause amputation. If your firm has such equipment, has more than 10 employees and is identified by a targeted SIC code (e.g., 2011-Meat Packing Plants, 3444-Sheet Metal Work) then you might be selected for a site inspection by OSHA. Before proceeding with the inspection, OSHA 200 and OSHA 300 logs will be reviewed to identify recorded amputations. The inspection will focus on any machinery and equipment associated with amputations and identified target equipment (e.g., benders, roller and shapers, press brakes, casting machinery, conveyors, grinders, drills, saws shears, etc.). They will pay particular attention to employee exposures to nip points, pinch points, shear points, cutting actions and other points of operation. A citation will be issued for any violations to the OSHA Control of Hazardous Energy or any other applicable safety standard. Page 7 of 10

10 How Do We Achieve LOTO Excellence? Post-citation, crash programs can be expensive. Compliance with the LOTO regulations does not have to be expensive if planned for and purposefully implemented. The basic steps involved are: Actions How Applied EHS Can Help 1. Develop a written Applied EHS has written numerous successful program with all programs and can develop or review and update required elements. your program. 2. Identify equipment with Applied EHS can consult with you to develop a multiple energy sources strategy or review all equipment to determine serviced most often. whether a written ECP is required. 3. Train employees. Applied EHS staff can train your Affected and Authorized Employees in the classroom or using on-the-job training. 4. Write ECPs for the most often serviced equipment. 5. Write new ECPs, as needed for service or maintenance. 6. Inspect your program implementation. 7. Integrate LOTO into your contractor orientations Applied EHS can write critical ECPs or model the ECP writing process for your Authorized Employees. Applied EHS has trained Authorized Employees to write ECPs through our documented on-the-job training process to write them for repair or maintenance tasks as they arise. Applied EHS can develop an inspection plan for scheduling, conducting and documenting the required annual inspections and train your staff in most effective methods. Applied EHS can tailor your program to your use of contractors and develop contractor orientation materials to communicate LOTO requirements to contractors and their employees. Following these steps may not reduce the potential for OSHA outreach initiative-driven inspections but will reduce the risk to your employees and reduce the likelihood of receiving citations and associated fines if your company is inspected. Page 8 of 10

11 About Applied EHS Applied EHS Management has the expertise to make your firm compliant with these or other OSHA regulations and help make your workplace safer. Our staff has a wealth of Health and Safety management experience in operations environment with a broad range of industries. Our focus is on your health and safety needs. Our approach is to partner with your operation, maintenance and safety staff to implement employee protection programs that are compliant, performance-based and usable. Our field-experienced specialists have managed safety programs at operating industrial and utility facilities. From regulatory compliance to management oversight, our staff has the skill, training and experience necessary to develop and implement effective environmental health and safety programs. To assist you with understanding and applying the LOTO standard, Applied EHS offers some additional services, including: Conducting health and safety audits to uncover any deficiencies you may have in your present LOTO program; Developing a LOTO program to cover all aspects of your firm s or facility s specific situation; Assisting you with writing Energy Control Procedures using efficient software tools; Training for LOTO Authorized and Affected Employees, inspectors and staff who will be writing Energy Control Procedures; Assisting with addressing LOTO or any other OSHA inspection citations. Please contact us at your earliest convenience if we can assist your organization with achieving full compliance and performance excellence for the OSHA LOTO standard or any other Environmental, Health and Safety requirement. Page 9 of 10