Control of Hazardous Energy Most Frequently Cited LOTO

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Control of Hazardous Energy Most Frequently
Cited LOTO Requirements in General Industry

• Joint EFCOG/DOE Chemical Management Workshop

Bob Isiminger, PE, CSP March 24, 2011
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Most Frequently Cited LOTO Requirements in
General Industry

• General Industry
• 1910.147
• OSHAs control of hazardous energy
  (lockout/tagout) standard was the sixth most
  cited standard in 2010.
• 1910.147 11,064 Cited Violations with
  18-Mil in Initial Total Penalties from Oct 1,
  2007 to Sept 20, 2010

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Most Frequently Cited LOTO Requirements in
General Industry

• LOCKOUT/TAGOUT VIOLATIONS
• 1910.147 Standard Violations
• 1910.147 - This standard lays out the minimum
  performance requirements for the control of
  hazardous energy during the maintenance and
  servicing of machinery. The standard requires
  that lockout be used for equipment designed with
  lockout capability. Lockout/tagout procedures
  should be followed during maintenance or repair
  operations to ensure that power sources are
  locked in the off position and clearly marked
  with a tag so other workers do not turn on a
  machine by mistake. The standard also contains
  criteria for establishing an effective program
  for locking out devices.
• Top 5 provisions cited Oct 1, 2007 to Sept 20,
  2010
• 1910.147 (c)(4)(i) Failure to develop
  procedures for energy control
• 1910.147 (c)(1) Failure to establish a program
• 1910.147 (c)(6)(i) Failure to conduct periodic
  inspections
• 1910.147 (c)(7)(i) Lack of employee training
• 1910.147 (c)(4)(ii) Inadequate procedures
• Top 5 sections - 7,303 Citations with 12.3Mil
  Initial Penalties

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Most Frequently Cited LOTO Requirements in
General Industry

• Other Requirements for LOTO in General Industry
• 1910.217 Mechanical power presses
• 1910.218 Forging machines
• 1910.269 Electric power generation,
  transmission, and distribution

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Most Frequently Cited LOTO Requirements in
General Industry

• Other Requirements for Locking, Blocking, or
  Permitting in General Industry
• 1910.146 Permit-required confined spaces
• 1910.178 Powered industrial trucks
• 1910.179 Overhead and gantry cranes
• 1910.180 Crawler locomotive and truck cranes

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Most Frequently Cited LOTO Requirements in
General Industry

• Other Requirements for LOTO in General Industry
• 1910.269
• Requirements for the operation and maintenance of
  electric power generation, transmission, and
  distribution installations.

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Most Frequently Cited LOTO Requirements in
General Industry

• Other Requirements for LOTO in General Industry
• 1910.269 Requirements for Deenergizing for
  Employee Protection
• 1910.269(d)requirements for the control of
  hazardous energy sources in electric power
  generation installations
• 1910.269(m)requirements for deenergizing of
  transmission, and distribution lines and equipment

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Most Frequently Cited LOTO Requirements in
General Industry

• Other Requirements for LOTO in General Industry
• 1910.333(b) Selection and use of work practices
• OSHAs control of hazardous energy
  (lockout/tagout) for working on or near exposed
  deenergized parts.
• 1910.333(b) 315 Violations with 645,725 in
  Total Penalties from Oct 1, 2007 to Sept 20, 2010

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Most Frequently Cited LOTO Requirements in
General Industry

• LOCKOUT/TAGOUT VIOLATIONS
• 1910.333(b) Standard Violations
• 1910.333(b) - These requirements apply to working
  on or near exposed deenergized parts.
• Top 5 provisions cited Oct 1, 2007 to Sept 20,
  2010
• 1910.333 (b)(2) Failure to lock out or tag for
  energy control
• 1910.333 (b)(2)(i) Failure to maintain a
  written program and make it available for
  inspection by employees
• 1910.333 (b)(2)(v)(A) Failure to determine safe
  procedures for deenergizing circuits and
  equipment before circuits or equipment are
  deenergized
• 1910.333 (b)(2)(v)(B) Failure to disconnect
  determine safe procedures for deenergizing
  circuits and equipment before circuits or
  equipment are deenergized
• 1910.333 (b)(2)(v)(D) Failure to block or
  relieve stored non-electrical energy in devices
  that could reenergize electric circuit parts to
  the extent that the circuit parts could not be
  accidentally energized by the device

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Most Frequently Cited LOTO Requirements in
General Industry

• WHY LOCKOUT/TAGOUT
• Hazardous energy in the workplace

The son of the owner of a commercial drywall
construction company, who was also an employee of
the company, was preparing an aerial lift for a
job and had replaced two battery terminals. He
had raised the aerial boom and was reaching
toward the battery compartment across the metal
enclosure that houses the lifts toggle controls
when the boom dropped and pinned him to the
control panel. His father discovered him and
summoned emergency responders but he died at the
site.
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Most Frequently Cited LOTO Requirements in
General Industry

• CONTROLLING HAZARDOUS ENERGY
• Investigation findings
• The employee did not use lockout procedures while
  he was working on the lift and did not block the
  boom to prevent it from dropping.
• The owner had not reviewed the lifts instruction
  manual with the victim or other company
  employees.
• Although the company had more than 10 employees,
  it did not have a safety committee.
• The lifts emergency valve, hydraulic hoses and
  fittings, and electrical wiring were inspected
  after the accident and were not defective
  however, the on/off key switch had been bypassed
  so that the operator could use the toggle
  switches without using the key.
• The battery charging system was missing a fuse
  that would stop the system from charging and the
  spring-loaded toggle switches that controlled the
  boom did not have guards to prevent accidental
  contact.

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Most Frequently Cited LOTO Requirements in
General Industry

• DOES OSHA CITE DOE FOR VIOLATIONS?
• Bonneville Power Admin-Snohomish region (WA)
  serious violation
• Cited for Three Serious Violations on February
  20, 2009.

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Most Frequently Cited LOTO Requirements in
General Industry

• QUICK TUTOR ABOUT CONTROLLING HAZARDOUS ENERGY
• To control hazardous energy, you have to prevent
  it from being transmitted from its source to the
  equipment that it powers. You can accomplish that
  by doing the following
• Identify energy sources.
• Deenergize equipment by isolating or blocking the
  energy sources.
• Dissipate potential (stored) energy that could
  affect the equipment.
• Lock out the equipments energy-isolating
  devices.
• Tag out the energy-isolating devices only if you
  cant lock them out.

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Most Frequently Cited LOTO Requirements in
General Industry

• LOCKOUT/TAGOUT according to Naval Facilities
  Engineering Command (NAVFAC)
• Direct causes of mishaps
• Lack of notification prior to reenergizing
• Not verifying deenergized state
• Failure to adequately bleed pressurized system
  before disassembly
• Unauthorized work
• Lack of communication between workers
• Workers ignoring safety procedures

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Most Frequently Cited LOTO Requirements in
General Industry

• LOCKOUT/TAGOUT according to NAVFAC
• Indirect causes of mishaps
• Lack of Lock-out/tag-out program
• Workers not adequately trained or supervised
• Approved safety plan not implemented
• Regular site safety inspections not performed
• Lack of and/or use of safety equipment

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Most Frequently Cited LOTO Requirements in
General Industry

• COMMON QUESTIONS ABOUT LOCKOUT/TAGOUT
• What happens if I attach a lockout or tagout
  device but Im not available to remove it?
• Your employer can authorize another employee to
  remove the device if that employee is trained to
  do so and follows a documented energy-control
  procedure. The procedure must ensure that youre
  not available to remove the device, that someone
  has tried to contact and inform you that another
  employee has removed the device, and that you
  know the device has been removed before you
  return to work.

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Most Frequently Cited LOTO Requirements in
General Industry

• COMMON QUESTIONS ABOUT LOCKOUT/TAGOUT
• How do I deal with locked-out or tagged-out
  equipment when work shifts change?
• You can adapt your energy-control procedures to
  shift changes as long as the procedures ensure
  that employees on all shifts are protected.

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Most Frequently Cited LOTO Requirements in
General Industry

• COMMON QUESTIONS ABOUT LOCKOUT/TAGOUT
• How do I deal with locked-out or tagged-out
  equipment after long-term shutdowns?
• You should also have an additional energy-control
  procedure to protect employees if they must
  restart equipment after long-term shutdowns.
  Determine who will be responsible for monitoring
  any lockout and tagout devices that control
  energy to the equipment. Include steps in the
  procedure for protecting employees if they need
  to remove or change parts while the equipment is
  shut down. Do not restart equipment until you are
  absolutely certain that it is working properly.

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Most Frequently Cited LOTO Requirements in
General Industry

• COMMON QUESTIONS ABOUT LOCKOUT/TAGOUT
• What if I contract service or maintenance on my
  equipment?
• You and the contractor must understand one
  anothers lockout and tagout procedures. Review
  your contractors energy-control program before
  the contractor does any on-site work. Your
  employees must also understand and comply with
  the contractors energy-control program.

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Most Frequently Cited LOTO Requirements in
General Industry

• COMMON QUESTIONS ABOUT LOCKOUT/TAGOUT
• How do I decide whether to lockout or tagout a
  device?
• If you can lock out an energy-isolating device,
  then you must lock it out before you service the
  equipment that it controls. If you cant lock out
  an energy-isolating device, then you must tag it
  out. Remember that you must ensure that the
  hazardous energy is controlled just as
  effectively with the tagout device as it would be
  with a lockout device.

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Most Frequently Cited LOTO Requirements in
General Industry
Questions?
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Most Frequently Cited LOTO Requirements in
General Industry

• GROUP LOCKOUT/TAGOUT
• In many workplaces a group of authorized
  employees may need to service equipment that has
  several energy sources and several
  energy-isolating devices.
• Under Group Lockout, just one designated person
  in the group assumes Responsibility for securing
  each energy-isolating device. There are a number
  of variations of group lockout the group lockbox
  variation reduces the number of locks and makes
  it easier for employees to coordinate their
  activities.

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Most Frequently Cited LOTO Requirements in
General Industry

• EXAMPLE OF GROUP LOCKOUT PROCEDURE
• Step 1 A designated, authorized employee
  (designated to coordinate affected work forces
  and ensure continuity of protection) in the group
  secures each energy-isolating device with a
  personal lock.
• Step 2 The same (designated) authorized employee
  places the key that fits each lock in a group
  lockbox with a multilock hasp.
• Step 3 The other authorized employees in the
  group secure the lockbox they each attach their
  personal locks to the box before beginning
  their service work.
• Step 4 After each employee finishes service work
  on the equipment, that employee removes his
  personal lock from the lockbox.
• Step 5 After all the employees have finished
  their service work and removed their personal
  locks from the lockbox, the authorized employee
  who placed the key in the box removes it.
• Step 6 The authorized employee uses the key to
  remove the lock on each energy-isolating device.

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Most Frequently Cited LOTO Requirements in
General Industry
Questions?
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Most Frequently Cited LOTO Requirements in
General Industry

• Navigating OSHAs public website
• Hint Linked-In Use the links.

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Most Frequently Cited LOTO Requirements in
General Industry

• Navigating OSHAs public website
• The Blue link takes us to this LOI.

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Frequently Cited LOTO Requirements in General
Industry

• General IndustrySubpart S
• OSHAs Compliance DirectiveThe Control of
  Hazardous Energy Enforcement Policy and
  Inspection ProceduresDirective Number CPL
  02-00-147

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Most Frequently Cited LOTO Requirements in
General Industry
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Most Frequently Cited LOTO Requirements in
General Industry
Questions?
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Any Questions?