out / tag ut€¦ · required, and solely for lockout/tagout purposes. ensure that employees know...

Teach Locks - Tags Audit

LOCK OUT / TAG OUT

Shannon LozeauMS, CIH, CSP, TURP

ECO DEVENS ROUND TABLE

April 2018


OSHA’s Top 10 List (9/2017)

Standard Number of citations

1. Fall Protection – General requirements (1926.501) 6,072

2. Hazard communication (1910.1200) 4,176

3. Scaffolding (1926.451) 3,288

4. Respiratory protection (1910.134) 3,097

5. Lockout/tagout (1910.147) 2,877

6. Ladders (1926.1053) 2,241

7. Powered industrial trucks (1910.178) 2,162

8. Machine guarding (1910.212) 1,933

9. Fall protection – Training requirements (1926.503) 1,523

10. Electrical – Wiring methods (1910.305) 1,405


LOTO Basics

• 29 CFR 1910.147

• Purpose

• Exemptions

• Application

• Affected Employee

• Authorized Employee

• Energy Sources• Electrical,

• Mechanical,

• Hydraulic,

• Pneumatic,

• Chemical,

• Thermal, or

• Other energy


Education – Who…What

Affected

• Purpose for the procedures being used

Authorized

• Recognition of hazardous energy

• Type/magnitude of energy in workplace

• Means/methods of isolating/ controlling energy

• Means to verify effectiveness of energy controls

• Purpose for the procedures being used

Others

• Told of procedure and prohibition related to attempting to restart equipment that is LOTO.


Education - When

Initially, or prior to performing service or maintenance

Retraining is required if:• Change in job assignments• Change in machines• Change in energy control procedures• Equipment or processes present new hazards• Inspections reveal deficiencies in employee's

knowledge of energy control procedures• Retraining must reestablish employee proficiency


Application of the Energy Control Procedure

1. Prepare for shutdown

2. Shut down equipment

3. Isolate all energy sources

4. Apply locks & tags

5. Release stored energy

6. Verify equipment isolation

7. Perform the task

8. Release from Lockout

Notify Shutdown

Isolate Attach

Release Verify

Service Release


My ProgramDefining the Expectation


Written Program

My written program outline


Consistency? What’s the message?


My Summary Sheet


Key Control???

How many people have the key to that lock?

Where is the “single key” kept?

Do you have all the extra keys that came with the locks?

Do people know where you keep them?


My Equipment ListIdentifying the Equipment and Why LOTO applies or not


8 Point Exclusion

1. No stored energy

2. Single energy source

3. Isolation completely deenergized

4. Completely isolated

5. (1) LOTO device

6. LOTO devise exclusive control

7. No hazard to others

8. No accidents


My Equipment List


Equipment Specific ProcedureSpecific Procedures - Many ways to accomplish this!


Energy Control Procedures

• Must be specific to each type of machine and equipment you are working on

• Must include – Statement of intended use

of the procedure – Steps for shutting down and

securing machines and equipment

– Steps for placing, removing, and transferring of lockout devices

– Requirements for testing and verifying effectiveness of lockout devices

1. Energy Types2. Shut down3. Isolation4. LOTO

application5. Release6. Verified OK


My Current Procedures


My Next Version of Procedures


My Next Version of Procedures cont’d


AuditingEnsuring your folks are applying the program as you intended.


Periodic Inspections

• Performed at least annually

• Conducted by authorized employees

• Intended to correct inadequacies identified in program

• Certified


Certification Requirements

• Identification of equipment or machinery

• Date of inspection

• Names of employees involved in the inspection

• Name of person(s) performing inspection


Periodic Inspection Form

Simple Detailed


Some Field Audit ExperiencesAuditing the program YOU created….


Auditing the Program

ProtocolSectionQuestion# Question QuestionRefs Reference

Lockout/Tagout 1Does the site have a written hazardous energy control program?

The following elements should be included in the program: General Energy control procedures; Equipment specific procedures for multiple energy sources; Protective materials and hardware; Periodic inspections of procedures; Employee training; Application o

Ref: 29 CFR 1910.147(c)(1); EHS Standard ### Control of Hazardous Energy - Section 2.2 a through f

Lockout/Tagout 2

Are written energy control procedures available for each piece of equipment that does not meet all 8 exceptions listed in OSHA 1910.147(c)? OSHA 1910.147 (c)(4)(i) - Exception: The employer need not document the required procedurefor a particular machi

Procedures must include: Scope and purpose; Specific procedural steps for placement removal and transfer of lockout devices and the responsibility for them. Specific procedural steps for shutting down, isolating, blocking, and securing hazardous energy;

Ref: 29 CFR 1910.147(c)(4); EHS Standard ### Control of Hazardous Energy - Section 2.2

Lockout/Tagout 3Has each energy control procedure been reviewed annually by an authorized employee?

There are special situations to recognize with this issue. Energy control procedures used less than once per year need be inspected only prior to use. Similar machines and/or equipment (e.g., those using the same type and magnitude energy) which have th


Lockout/Tagout 4Has adequate initial training and retraining been conducted for authorized, and affected employees?

Review training material and records. Interview several employees during the site walk-through. Content of the authorized employee training program: Recognition of applicable hazardous energy sources; Type and magnitude of the energies in work area; Met


Lockout/Tagout 5

Do observations made during the site walk-through confirm that the hazardous energy control program has been implemented and is effective?

Verify that locks and tags specified for lockout/tagout use by the site hazardous energy control program are being used as required, and solely for lockout/tagout purposes. Ensure that employees know where to obtain procedures and equipment and can ident

Ref: 29 CFR 1910.147; EHS Standard ### Control of Hazardous Energy -Section 2.5 b and c

Lockout/Tagout 6

Does the hazardous energy control program include provisions for coordinating with outside contractors and is the method of coordination being utilized and effective?

Verify that lockout/tagout is a specific requirement within the site’s contractor safety program and that it addresses the use of energy control procedures. Ref: 29 CFR 1910.147(f)(2)


Auditing the Program

Consider putting a “periodic inspectioncertification” statement on your LOTOEquipment Specific Procedure and havingpeople complete the form every time theydo the LOTO on that equipment. Probablybetter way to go for infrequent LOTO uses.


Some Field Audit ExperiencesWhat’s happening in the “Real World”?


Injuries Still Happening !!!!!!

• Worker inside kiln died when automated system locked and activated it (4/2017)

• Conveyor Belt breaks bones in worker’s hand and arm: $140K OSHA fine (12/16/15).. Wegmans Food Market Bakery. 3rd fine in 5 years.

• a sanitation crew member losing his fingertip when it caught in the pinch point of an operating conveyor he was cleaning, and

• a mechanic suffering a first-degree burn on his wrist when steam released while he attempted to repair a valve.

• Tootsie Roll temp loses part of finger: $55k OSHA fine (2/2/16 Cambridge, MA)

• Machinery Hazards: $88k OSHA fines (12/2015- GE)


LOTO done wrong…..

From OSHA LOTO training

Unjamming a printing press without de-energizing it

Troubleshooting



Employee servicing printing press without de-energizing equipment Employee trying to adjust

machine when runningFrom OSHA LOTO training



From OSHA LOTO training


LOTO done better…..


AllegedlyReal Photos


Let’s talk turkey….

• Do you have a LOTO program?• Do you have equipment specific

procedures?• Do you train…different levels, but nearly

everybody at the end of the day.• Do you do periodic inspections?

Correctly?

• Where do you find your challenge? • Any lessons learned to share?

out / tag ut€¦ · required, and solely for lockout/tagout purposes. ensure that employees know...

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