Lockout Myths & Misconceptions Chad Ignatowski Office: (616) 696-3887 Cell: (616) 240-2739 Email: Chad@AccessSafety.biz www.accesssafety.biz
DICUSSION TOPICS Lockout program elements Lockout Myths/Gaps/Misconceptions related to: Policy Procedures Training Periodic inspections Contractors Hardware/equipment
LOCKOUT PROGRAM ELEMENTS Lockout policy Lockout procedures Training Periodic inspection Contractors Hardware/Tags/Labels Risk assessment Enforcement & Mgmt PPE Equipment
LOCKOUT POLICY or For effective program implementation, a group of company stakeholders should develop a site specific lockout policy based on the company s hazards, equipment and exposures.
LOCKOUT POLICY or Part 85 (1910.147) requires that a lockout policy is written.
LOCKOUT POLICY or MIOSHA allows employers to utilize a general lockout procedure documented in a policy in lieu of documenting lockout specific procedures for each different machine.
LOCKOUT POLICY A procedure must provide sufficient detail and specificity to permit an authorized employee to safely and effectively utilize energy control measures to service/maintain each machine or piece of equipment covered within the scope of the procedure. OSHA used the word specific in the standard to describe the elements of the procedure. This was done to emphasize the need for detailed procedures because over-generalization does not provide authorized employees sufficient information to effectively control the hazardous energy to which they are exposed. The use of generic energy control procedures alone are unacceptable, if generic procedures do not meet the provisions set forth in 1910.147(c)(4)(ii). (CPL 02-00-147)
LOCKOUT POLICY GAPS Compliance driven vs. performance driven Developed from a single resource No development and implementation process Not site-specific Not a living document Not enough content Too much content
LOCKOUT PROCEDURE or A machine is considered to have two hazardous energy sources when an electric disconnect isolates a hydraulic system, thus requiring a machine-specific lockout procedure.
LOCKOUT PROCEDURE or Lockout applies when servicing forklifts and other mobile vehicles.
LOCKOUT PROCEDURE OSHA s compliance directive clarifies that the rules apply to vehicles such as forklifts, cars, trucks, and other vehicles. Whether they re powered by gas, propane, or electricity, vehicles have several types of hazardous energy that you need to disconnect and lock out during repairs. In some cases, the person doing the repairs is completely protected by removing the ignition key if he s the only person who has the key. Depending on the work being done, you might have to take other steps such as disconnecting the battery or inserting blocks to keep parts in place. OSHA says you should follow the vehicle manufacturer s recommendations for how to do service and maintenance work. (CPL 02-00-147)
LOCKOUT PROCEDURE or MIOSHA requires employers to deenergize (lockout) equipment for all service tasks.
LOCKOUT PROCEDURE Servicing and maintenance activities are permitted without machine or equipment LOTO pursuant to the minor servicing exception -- 1910.147(a)(2)(ii) note. Minor servicing activities, which take place during normal production operations and which are routine, repetitive, and integral to the use of machine/equipment for production, are not covered by the LOTO standard if alternative methods provide effective employee protection from hazards associated with the control of hazardous energy (e.g., unexpected start-up). Compliance with the machine guarding requirements of Subpart O is an example of such alternative measures.(cpl 02-00-147)
MAJOR & MINOR SERVICE FACTORS MAJOR MINOR More than one performing task Guards removed with tools Equip removed or disassembled Additional tools for removal needed Set up, PMs, scheduled cleaning, repairs Task is not predictable Task doesn t exist during normal conditions Specific training to perform task Specific knowledge/skills to perform task Production process can t continue if task not performed Task creates a major unanticipated interruption to production process One performs task Guards only removed or by-passed with additional guards/devices in place Equipment not dissembled Tools/parts readily available Minor servicing occurs frequently Task is predictable Task occurs normally during production process Operator can/does perform task Task only interrupts production in short durations Production process can continue to function if task is not performed
LOCKOUT PROCEDURE or Lockout is not feasible during die setting procedures.
LOCKOUT PROCEDURE The changing of dies on a full- or part-revolution mechanical power press requires the employer to establish a die-setting procedure that employs point-of-operation safeguarding method(s), such as the safe usage of an Inch or Jog safety device for die set-up purposes together with LOTO. (CPL 02-00-147)
LOCKOUT PROCEDURE or The double block and bleed method is always required when isolating hazardous materials (i.e. steam, flammable gas, corrosives, etc).
LOCKOUT PROCEDURE or During the utilization of double block and bleed, the drain/vent/dissipating valve in between two in-line valves must be locked or tagged in the open position.
LOCKOUT PROCEDURE or If a machine has hazardous energy sources beyond electrical, an isolating plug and cord must be locked in an enclosure.
LOCKOUT PROCEDURE 1910.147(a)(2)(iii) This standard does not apply to the following: Work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.
LOCKOUT PROCEDURE or An employee servicing cord and plug connected electric equipment is not required to be an authorized employee.
LOCKOUT PROCEDURE As long as the method of isolating the energy to the equipment is limited to unplugging the equipment and maintaining control of the plug, 1910.147 does not require an employee who performs maintenance on cord and plug connected equipment to be an "authorized employee. (04/03/12 interpretive letter)
LOCKOUT PROCEDURE In this situation, contracted employees are considered "authorized employees" pursuant to 1910.147. An "affected employee" becomes an "authorized employee" when that employee's duties include the performance of servicing or maintenance as defined under 1910.147(b). When employees are working on machines or equipment in which the uncontrolled hazardous energy could cause injury to employees, both the host employer and the contractor employer have independent obligations to provide the protection under the standard for their respective employees. OSHA recognizes that the host employer often will have greater familiarity with the energy control procedures used at the host facility. (11/16/00 interpretive letter)
LOCKOUT PROCEDURE or In some cases machine guarding can be used in lieu of lockout.
LOCKOUT PROCEDURE It is important to emphasize that the machine guarding requirements of 29 CFR Part 1910, Subpart O standards complement the requirements for LOTO. In some instances, an employer may avoid the requirements of the LOTO standard, if he eliminates exposure to servicing and maintenance hazards by using machine guarding techniques compliant with those standards. (CPL 02-00-147)
GROUP LOCKOUT or When performing group lockout with a contractor, only a host authorized employee may shutdown the equipment and verify isolation and de-energization.
GROUP LOCKOUT Any affected or authorized person may shut down a machine or piece of equipment, as long as that person follows the procedures established for shutting down the machine or piece of equipment in accordance to 1910.147(d)(2). Prior to the time that the authorized employee(s) start to work on a machine or a piece of equipment that has been locked out or tagged out, the authorized employee(s) must verify isolation and de-energization of the machine or the piece of equipment. While isolation and de-energization may be accomplished by a single authorized employee (a "primary authorized employee") in a group lockout/tagout scenario, each authorized employee has the right to participate in the verification process, if he/she chooses to do so. (11/16/00 interpretive letter)
LOCKOUT PROCEDURE GAPS Unstructured development & implementation process Time constraints Lacking specificity or content Confusing Magnitudes not addressed Equipment No equipment/procedure inventory No equipment identifiers Isolation mechanism New equipment evaluation Safety guards/devices Proper function
LOCKOUT PROCEDURE GAPS Dissipation methods & points not addressed Procedures are not task-specific Lack of hazard identification Lack of enforcement, accountability, ownership Language barriers Lacking group lockout, shift change, emergency lock removal, contractor protocols Group lockout Primary Authorized Employee not established Other Authorized Employees not in control of energy sources Other Authorized Employees unaware of hazards
LOCKOUT TRAINING or MIOSHA will accept a generic video or computer-based training as a company s only means to comply with Part 85 (1910.147) training requirements.
LOCKOUT TRAINING Self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. However, unless the training program is specific to the servicing that will be performed by an individual employee, use of generic videos or computer-based training by itself would not be sufficient to meet the intent of OSHA's LOTO training requirements. OSHA urges employers to be wary of relying solely on generic, packaged training programs in meeting their training requirements because training must be relevant for the employees' actual servicing and maintenance work activities. Specifically, training under LOTO includes site-specific elements and, very importantly, it must be tailored to employees' assigned duties. (CPL 02-00-147)
LOCKOUT TRAINING or Electronic swiping of an employee s identification badge satisfies MIOSHA s requirement to certify/document lockout training.
LOCKOUT TRAINING Generally, electronic certification of training is acceptable provided the electronic certification meets the requirements of the standard. For example, 29 C.F.R. 1910.147(c)(7)(iv) requires an employer to certify that employee training has been accomplished and that the certification contains each employee's name and dates of training. Electronic swiping of an employee identification badge would be acceptable under the standard if it records each employee's name and the date of training and the employer includes, as part of the badge swiping, a component that certifies the training occurred. (09/22/2014 interpretive letter)
LOCKOUT TRAINING or MIOSHA requires annual lockout training.
LOCKOUT TRAINING 1910.147(c)(7)(iii) Employee retraining: (A) Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures. (B) Additional retraining shall also be conducted whenever a periodic inspection under paragraph (c)(6) of this section reveals, or whenever the employer has reason to believe that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures. (C) The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary.
LOCKOUT TRAINING or A contractor is responsible for training their employee(s) in every phase of the lockout procedure, including shutdown procedures even when the host employer assigns an employee to shutdown the equipment.
LOCKOUT TRAINING An contractor is not required to employ or train your own representative to shut down the equipment if the host employer has assigned an employee to shut down the equipment and that employee follows the established shutdown procedure. However, you are required to train each authorized employee in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control as described in 1910.147(c)(7)(i)(A). (11/16/00 interpretive letter)
LOCKOUT TRAINING GAPS Don t identify Authorized, Affected, Other Language barriers Competent trainer Competent Authorized personnel Lack of hazard recognition Understanding Service tasks No practical training No Continual/Follow-up training No test to qualify learning Compliance driven Lack of management involvement & reinforcement
PERIODIC INSPECTION or Each individual lockout procedure must be inspected annually.
PERIODIC INSPECTION An employer may group distinct procedures associated with similar machines or equipment and consider the group of distinct procedures to be a single procedure for purposes of conducting a periodic inspection, if the machines or equipment in the group have the same or similar types of control measures.(cpl 02-00-147)
PERIODIC INSPECTION or An employer can annually inspect a representative number of Authorized employees.
PERIODIC INSPECTION Grouping energy control procedures for same or similar machines or equipment for inspection purposes may streamline the inspection and review process, since there will be a smaller number of procedure groups than individual procedures. Thus, an employer may elect to group procedures and then inspect a representative number of such employees implementing one procedure within each group. This approach is acceptable as long as the inspection sampling reasonably reflects plant servicing and/or maintenance operations and hazardous energy control practices for the procedures being inspected. (CPL 02-00-147)
PERIODIC INSPECTION GAPS A large number of procedures A large number of Authorized employees Time constraints Lack of rule understanding System of documentation Lack of human resources
CONTRACTORS or A host employer must train a contractor s Authorized employees before servicing equipment at a host s facility.
CONTRACTORS If outside contractors service or maintain machinery, the on-site employer and the contractor must inform each other of their respective lockout or tagout procedures. (CPL 02-00-147) 1910.147(f)(2)(ii) The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer's energy control program.
CONTRACTORS or Contracted employees servicing a piece of equipment are considered affected employees under the lockout standard when the host employer performs the shutdown procedures.
CONTRACTORS In this situation, contracted employees are considered "authorized employees" pursuant to 1910.147. An "affected employee" becomes an "authorized employee" when that employee's duties include the performance of servicing or maintenance as defined under 1910.147(b). When employees are working on machines or equipment in which the uncontrolled hazardous energy could cause injury to employees, both the host employer and the contractor employer have independent obligations to provide the protection under the standard for their respective employees. OSHA recognizes that the host employer often will have greater familiarity with the energy control procedures used at the host facility. (11/16/00 interpretive letter)
CONTRACTOR GAPS Lack of communication between host & contractor Lack of training of employees regarding interaction Coordinated group lockout efforts Contractors do not have specific procedures Host not accountable for contractor s activities
HARDWARE or To comply with the lockout standard, an employer may modify a standard on/off switch with a bracket that allows the switch to function normally and also allows it to be lockable.
HARDWARE The bracket may be acceptable for lockout purposes if the referenced switch is an energy-isolating device 1 and the bracket reliably ensures that the switch and the related equipment cannot be operated until the lockout device is removed. However, it is important to point out that your client's installation of this bracket constitutes a modification to the electrical box and the dead-front switch, which does not comply with paragraph 1910.303(a), Approval, requires electric equipment to be approved. 2 Pursuant to Subpart S standards, independent, third party testing is required for certain equipment and materials to be acceptable for workplace use. (05/13/2003 interpretive letter)
HARDWARE GAPS Equipment unavailable Locks Not standardized Not labeled or legible Used for purposes other than lockout Not applied by all Authorized personnel Language barriers Tagout not applied properly
LOCKOUT or We are half way through this presentation.