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Safety Info Posts - Lockout Tagout
Written by Bryan Haywood   
Friday, 22 April 2011 19:09

Due to the significant risks associated with inadequate energy control procedures and the failure to properly implement effective energy control procedures, section 1910.147(c)(6)(i) REQUIRES that periodic inspections be performed AT LEAST ANNUALLY (based on twelve-month intervals) to verify that the procedures are adequate and they are being properly applied. OSHA believes that these periodic inspections will, in part, ensure that the employees involved with LOTO are familiar with their responsibilities and the employees maintain proficiency in the energy control procedures they implement.

NOTE: OSHA allows energy control procedures that are used less frequently than once a year (based on a twelve-month interval) be inspected only when used.

These periodic inspections MUST contain at least two components:
1) an inspection of EACH energy control procedure, and
2) a review of EACH employee’s responsibilities under the energy control procedure being inspected.

EACH energy control procedure required by §1910.147(c)(4) MUST be separately inspected to ensure that the energy control procedure is adequate and is being PROPERLY implemented by the authorized employee(s) in accordance with the LOTO standard.

NOTE: Energy control procedures that are not required to be documented, per the §1910.147(c)(4)(i) documentation exception, still eed to be inspected and reviewed to ensure that they are adequate and being properly utilized.

At a MINIMUM, these inspections MUST INCLUDE a demonstration of the procedures and MUST be performed while the authorized employees perform servicing and/or maintenance activities on machines or equipment. The inspections may be accomplished through random audits, plant safety tours, or planned visual observations. The inspector, who MUST be an authorized employee other than the one(s) utilizing the energy control procedure being inspected, MUST observe the implementation of the energy control procedure for the servicing and/or maintenance activities being evaluated and talk with employees implementing the procedure to determine that ALL the requirements of the LOTO standard are understood and being followed by employees.

NOTE: The authorized employee performing the inspection may be someone who previously has or currently implements the energy control procedure being inspected, as long as he is not implementing any part of the energy control procedure while it is being inspected. In the event a small business cannot meet this requirement, contained in §1910.147(c)(6)(i)(A), CSHOs shall evaluate the situation, on a case-by-case basis, in accordance with the impossibility affirmative defense. See Chapter 2, Section VI.B for additional guidance.

Specifically, the inspector must be able to determine whether:

1) the steps in the energy control procedure are being followed;

2) the employees involved know their responsibilities under the procedure; and

3) the procedure is adequate to provide the necessary protection, and, if inadequate, what modifications are needed.

Although not required by the standard, some employers develop, document, and utilize separate energy control procedures for individual machines or pieces of equipment when the standard would permit a single procedure to apply to the group of machines and equipment. An employer who exceeds the minimum requirements of the standard and develops distinct energy control procedures for individual pieces of machinery is NOT subjected to more extensive inspection and review obligations than an employer who groups a set of same or similar machines and develops a single, compliant energy control procedure for the set of machines. A grouping of individual procedures, meeting the criteria contained in this section, would be considered one procedure for periodic inspection purposes.

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. Refer to Section IX of the LOTO CPL for additional information on energy control procedures, including the performance criteria for procedure grouping.  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 as described above, 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.  If procedures are grouped for inspection purposes, the employer should consider selecting different individual procedures (from the group of same or similar procedures) each year for evaluation so that, over time, each individual procedure is eventually inspected as part of an inspection program. However, within a group of procedures, an employer may be justified in focusing more regularly on a subset of procedures that are more likely to be deficient or incorrectly implemented by employees, if institutional experience (e.g., accident rates associated with certain machinery) or other factors (e.g., the unusually large number of employees required to accomplish the servicing activity) support such a strategy. Regardless of the approach, these representative procedure inspections MUST reasonably reflect plant servicing and/or maintenance operations and practices.

NOTE: If the employer chooses to group and inspect energy control procedures for inspection purposes, the inspector must be an authorized employee who is not implementing the procedure that is being inspected. If the representative sampling reveals an energy control procedural problem associated with one of the procedures that have been grouped for inspection purposes, the employer MUST resolve the deviation or inadequacy with respect to EACH of the procedures associated with the group of machines or equipment.

On the other hand, some companies develop an elaborate generic energy control procedure and supplement the generic procedure with checklists or appendices to address various, distinct machinery and equipment in their facilities. This type of procedure, as well as those described above, may be considered a single energy control procedure (instead of multiple procedures) for inspection purposes, if all of the criteria contained in this chapter on grouping same or similar machines/equipment are met. However, if checklists or appendices address machinery/equipment that do not all use the same or similar types of control measures, the employer is REQUIRED to divide machinery and equipment referenced in the checklists or appendices into groups, such that the machines/equipment in any group have the same or similar types of control measures.  Once this is accomplished, an employer may inspect and review the generic energy control procedure in conjunction with each distinct group of machines/equipment referenced in the relevant checklists or appendices.

A review of each employee’s responsibilities under the procedure, in accordance with 1910.147(c)(6)(i)(C) and (D), is the second periodic inspection component. When lockout is used, the employer’s inspection MUST include a review of the responsibilities of EACH authorized employee implementing the procedure with that employee. When tagout is used, the employer MUST conduct this review with EACH AFFECTED AND AUTHORIZED employee.  However, in order to meet the review requirement, the inspector does NOT have toOBSERVED every authorized employee implementing the energy control procedure on the machine or equipment on which he is authorized to do servicing and/or maintenance. Rather, the inspector performing the inspection may observe and talk with a representative number of such employees implementing the procedure in order to obtain a reasonable reflection of the servicing or maintenance work practices being evaluated. In addition, to supplement this representative inspection sampling approach, additional supplemental reviews, as discussed in this section, MUST STILL BE PERFORMED WITH ALL AUTHORIZED EMPLOYEES WHO ARE REASONABLY EXPECTED TO IMPLEMENT the procedure during the year. Group meetings may be the most effective way to meet the review requirements and to re-establish employee procedure responsibilities and proficiency. With regard to the authorized employees (e.g., general plant maintenance personnel) who perform a multitude of servicing and/or maintenance tasks throughout an entire facility, it may not be practical for an employer to identify each of the procedures that these employees will implement during the year. However, before performing servicing or maintenance on a machine or piece of equipment, each authorized employee must have reviewed the inspection results from that machine or piece of equipment (or similar machine/piece of equipment, if machines/pieces of equipment have been grouped for inspection purposes). Among the acceptable methods for communicating inspection results to employees who were not identified previously would be to include the inspection review as part of an annual safety contact (if the review occurs prior to the employee's implementation of the procedure at issue) or in a pre-shutdown briefing (e.g., as part of the Preparation for shutdown requirements contained in §1910.147(d)(1)).  Employee retraining, if required by §1910.147(c)(7)(iii), for infrequently used energy control procedures must be performed prior to the start of the infrequent servicing/maintenance task. Obviously, the content and detail of this review will be determined by the results of the inspection's representative sampling. For example, if the result of a representative procedure sampling determines that no deficiencies exist, then this review may involve positive re-enforcement communications through individual or group meeting(s) regarding the employees' procedural responsibilities.

NOTE: Employee retraining is not required when inspections do not reveal any deficiencies.

A more comprehensive review between the inspector and each authorized employee is necessary if it is discovered that there are deviations from the energy control procedure being implemented or inadequacies in employee knowledge regarding the energy control procedure or its application. Corrective actions (e.g., enforcement of existing procedures) need to be instituted and retraining must be performed whenever any inspection reveals inadequacies in the employee's knowledge of, or use of, the energy control procedure. See 1910.147(c)(6)(i)(B) and 1910.147(c)(7)(iii)(B).

If the inspection reveals energy control procedure inadequacies, then a more detailed review with all employees must be performed to address new/modified employee responsibilities whenever there is a change in an energy control procedure. A modification in the procedure necessitates additional employee retraining [in accordance with paragraph (c)(7)(iii)] and certification [in accordance with §1910.147(c)(7)(iv)] to re-establish employee proficiency for all affected and authorized employees affected by the change in the procedure. (Refer to Section XVI of this Chapter for policy on employee training.) 

Additionally, employers must certify, in accordance with §1910.147(c)(6)(ii), that the prescribed periodic inspections have been performed. The certification MUST specify:

1) the machine or equipment on which the energy control procedure was used;
2) the date of the inspection;
3) the names of the employee(s) included in the inspection; and
4) the name(s) of the person(s) who performed the inspection.

The inspection records provide a means to determine employer compliance with the standard. Most importantly, the inspection process provides employers with the assurance that employees can safely service, maintain, and repair machines and equipment.

At one particular establishment, a work permit system (that identified the machine/ equipment being serviced/maintained and the authorized employees' names) had been developed with a section on the permit for an inspector to certify performance of all of the elements outlined in §1910.147(c)(6) of the standard. The inspector signed and dated the permit after the inspection was completed, thereby certifying, in accordance with the standard, that the periodic inspection had taken place. This method would meet the performance-oriented requirements for the inspection component of periodic inspections, if the inspector was able to determine whether:
1) the steps in the procedure are being followed;
2) the employees involved know their responsibilities under the procedure; and
3) the procedure is adequate to provide the necessary protection, and, if inadequate, what modifications are needed.

This work permit inspection technique may be especially useful where employees perform certain LOTO tasks infrequently.

NOTE: The American National Standard on the Control of Hazardous Energy - Lockout/Tagout And Alternative Methods (ANSI/ASSE Z244.1-2003; Section 5.6) contains Program review provisions that do not mandate all of the minimum requirements (e.g., additional affected employee review requirements, pursuant to §1910.147(c)(6)(i)(D), when tagout is used for energy control) that are prescribed in §1910.147(c)(6) of the LOTO standard.  The ANSI Z244.1-2003 consensus standard does not affect the employer's obligation to meet all of the requirements contained in the LOTO and related hazardous energy control standards.

 
 

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