Way back in April 2016, the OSHRC published a decision that settled the argument about LOTO procedures for "specific equipment/machines" and what they must contain.  This was an important decision that helped settle a lot of scuttlebutt about how LOTO gets managed in "complex" situations.  I like to explain to clients that LOTO in a chemical process is managed differently than how it is managed at a traditional manufacturing facility.  I put LOTO into three (3) buckets:

1) Simple LOTO

2) Traditional LOTO

3) Complex LOTO

Using 29 CFR 1910.147 as our road-map we can clearly see how these three (3) buckets play out.

1) Simple LOTO

"Simple LOTO" is a phrase used to describe the LOTO that OSHA discusses in 1910.147(c)(4)(i), where they exempt the facility from having to have a written machine/equipment specific LOTO procedure.  When the equipment meets ALL of the following eight (8) criteria, we call this a "SIMPLE LOTO":

(1) machine/equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down;

(2) machine/equipment has a single energy source which can be readily identified and isolated and will completely deenergize and deactivate the machine or equipment;

(4) machine/equipment is isolated from that energy source and locked out during servicing or maintenance;

(5) single lockout device will achieve a locked-out condition;

(6) lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;

(7) the servicing or maintenance does not create hazards for other employees; and

(8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

2) Traditional LOTO

The "Traditional LOTO" is what 1910.147 was written for.  OSHA really was not thinking about chemical plants/process areas when they wrote the standard.  I can't help but think that they were thinking of the "Big 3" Auto Makers when they were writing the standard.  The standard is easily applied in the traditional manufacturing setting.  Writing "machine/equipment" in this type of workplace is manageable and quite easy as the equipment falls somewhere between the "simple LOTO" and "complex LOTO" discussed below.

3) Complex LOTO

These are those LOTO's that would require an energy isolation plan be generated based on the scope of work, energy types and their magnitudes.  For example, a chemical process unit has 1,000 valves.  Applying 1910.147 in the strictest of terms, we would be required to have a "specific" LOTO procedure for each valve in the process and by doing so would make the LOTO program unmanageable.  However, just because we have a "complex" situation we are not exempted from having a WRITTEN energy control plan that identifies ALL the energy types, their magnitudes, the means/methods to isolate each source, and the means to verify each source is at a zero energy state (ZES).  From preparing an energy control plan for changing out a valve to preparing an energy control plan for isolating a Permit-Required Confined Space that could involve dozens of energy isolating devices.  

So in the PSM/RMP world, our LOTOs will fit into one of these three buckets and our written LOTO program should address how we define these three buckets and how we will manage the three buckets.

 
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