LOTO and Contractors
A contractor is hired to make repairs to a piece of equipment. This work will require the machine’s energy sources to be isolated per 1910.147. The facility has a machine specific procedure for said equipment. Contractor follows the machine specific procedure and uses their company’s LOTO locks per their written LOTO program/practices to lockout this piece of equipment. Right next to this piece of equipment that has been isolated using the contractor’s LOTO locks is another contractor installing a new and identical piece of equipment. The contractor’s that performed the lockout used a very popular brand of silver locks - some with blue bands and some with yellow bands. The host employer’s LOTO program uses “color” to identify their LOTO locks and they use a solid red lock for their energy isolations. The site has a contractor safety orientation program for all contractors and during said orientation they train all the contractors that site LOTO locks are red in color.
Does this sound familiar to anyone? Maybe your facility has a contractor safety orientation where LOTO locks are identified by color, shape or size for all the contractors so that they may be able to identify LOTO locks. Maybe your facility allows contractors to isolate machinery/equipment using their own LOTO locks. If any of this sounds familiar, this article may be of interest.
Lockout is the RULE, “minor servicing” is the exception
As human nature goes we know if we give an inch there are those who will take a mile. This belief could not be more real than in Lockout/Tagout and the “Minor Servicing” exception. The "rule" is to LOCK IT OUT and the “minor servicing” exception is just that, an exception to the rule. OSHA has set the bar pretty high for what we can claim as “minor servicing” and this article looks to dispel the myths behind this abused “exception”.
It is Lockout OR tagout... NOT BOTH
Here we sit ending year 2013, 20+ years after OSHA promulgated its Control of Hazardous Energy (e.g Lockout/Tagout) standard and yet we still see so much confusion regarding this safety critical standard. We get so much resistance on some of the most basic requirements of LOTO I thought it would be helpful to dispel two of the most common errors/misunderstandings we come across...
LOCKOUT/TAGOUT Methods and Sample Procedures (CAL-OSHA)
CAL-OSHA has published a very nice LOTO manual with many great tips for everyone, inside and outside of the state of CA! Failure to develop and follow lockout and blockout procedures before working on machinery is one of the major causes of serious injury and death in the USA. Workers can become electrocuted - or suffer permanent disfigurement - due to inadvertent activation of a machine while it is being maintained, repaired or adjusted. Many occupational injuries and deaths occur during the cleaning, adjusting, unjamming, and servicing of machinery. Here is a situation that could happen at your facility:
Why does OSHA permit the LOTO exception ONLY on electrical cord and plug equipment?
It is widely known that OSHA permits a worker who is in EXCLUSIVE CONTROL of an electrical plug when electrical is the ONLY energy source to perform their servicing and maintenance without the application of a lockout device on the plug. This is permitted by
1910.147(a)(2)(iii)(A) 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.
However, it is common to see LOTO programs apply this exception to other forms of energy; most notably air hoses and hydraulic hoses. But there is a HUGE difference in the practice of unplugged an electrically powered piece of equipment vs. unplugging a piece of equipment that is under pneumatic (e.g. compressed air) power. OSHA does NOT permit this exception to be applied to any other power source, other than electrical and here’s why.
OSHA's requirement for "machine specific" LOTO procedures and the "exception"
OSHA believes that because of the need to follow the steps in the energy control procedure carefully and specifically, and the number of variables involved in controlling hazardous energy, a documented procedure is necessary for most energy control situations. However, the Agency has determined that in certain limited situations, documentation of the procedure will not add markedly to the protection otherwise provided by the standard. These situations incorporate several common elements:
LOTO fatality while cleaning (NY FACE)
A male food production worker, 54, who was employed by a pizza dough manufacturing facility, sustained fatal injuries as a result of deep neck lacerations made by a steel blade on a dough machine. On the day of the incident, the victim and a co-worker were assigned to clean two dough machines, an "elevator" and a "divider". The "elevator" had three major components: a lifting mechanism, a hopper, and a steel blade ("dough chunker") that was located at the bottom of the hopper. The facility's lockout/tagout procedure required an operator to set the control buttons of the "dough chunker" to "Off" and "Manu" before turning off the main power switches. Prior to the incident, the victim turned OFF and locked the power switches, but left the "dough chunker" controls set to "On" and "Auto".
From a recent OSHA citation for LOTO, yes we still have problems!
Whenever I do LOTO training I always mention some of the more "interesting" methods used to control hazardous energy and in each class I always get accused of fudging the truth, as "no one can be that stupid". Well here is a 2013 LOTO citation from OSHA that is proof positive that we still have a ways to go until everyone takes LOTO as seriously as us...
LOTO Fatality - Caught in conveyor system (TN-OSHA II #28 - 2010)
A 51-year-old sanitation worker at a frozen-food packaging facility died after he collapsed while cleaning one of the conveyor lines. He was assigned to clean the North Pea Line. He opened the access doors on both sides of the cleaning pan blower housing in preparations for the cleaning. The equipment was not shut down nor locked out; the victim was not an authorized employee and therefore should not have been working on the equipment. However, he began work near an unguarded projecting-shaft end located on the inclined-conveyor-dead-end roller. His clothes apparently got twisted around the end of the shaft and he collapsed onto the conveyor. His supervisor was the first to notice him in the collapsed state and other workers called emergency assistance while basic first aid/CPR was provided. He was transported to a local hospital where he was examined and admitted. He died in the hospital the next day. No external signs of trauma and no musculoskeletal injuries to the victim were discovered by the medical staff. No evidence indicated he was asphyxiated by becoming entangled in the rotating shaft end. The victim was known to be diabetic and his blood-glucose levels were measured in the HIGH range in the ambulance and in the emergency room. It remains unknown if a diabetic state contributed to his demise.
A traditional LOTO fatality - worker started equipment on another worker (TN-OSHA #23)
A 57-year-old supervisor was killed while trying to determine why hydraulic oil was leaking from a cotton press machine. The press consists of a hydraulic pusher, tramper and bailer. The pusher and tramper sit on an elevated platform accessed by stairs; the bailers and operator console are located on the lower level. The cotton is blown into the pusher section by air through piping; the pusher pushes the cotton into the tramper section, the pusher retracts, and the tramper comes down to compact the cotton. The tramper rises and the process is repeated until a proper bale is formed. The victim noticed a steady stream of oil coming from the platform under the pusher section of the press. He told the press operator to shut the press down. He then went upstairs to the pusher section of the press where there was an access door on the right side which is interlocked with the pusher to shut it down when the door is opened. When the access door was opened, the victim still could not determine the source of the leak. He instructed a co-worker to remove the end and side panel of the pusher, but after looking inside, he could not see the leak. He told a co-worker that the only way he would be able to figure out where the leak was located was to operate the pusher. He told the co-worker to go downstairs to the control panel and tell the press operator to turn the press on and operate it. The victim was standing at the side of the pusher when the co-worker left to go downstairs. As instructed by the co-worker through hand signals, the press operator raised the tramper foot in manual mode and then stopped; there was no motion on the machine. The co-worker then gave the usual verbal signal to the victim, yelling “here we go.” He waited 5-10 seconds and heard no response from the victim. Interpreting the lack of response to mean it was clear to proceed, he told the press operator to turn on the pusher. The co-worker heard a yell. He found the victim lying inside the pusher, with the portion of his body from the knees to his feet remaining outside the pusher.
Clearing up a couple of LOTO myths
Over the last several years the SAFTENG team has been seeing some interesting concepts when it comes to Lockout/Tagout applications and methods. I want to air these out and get some dialogue started so that everyone can understand the errors of these myths...
Palletizer kills temporary worker, 21, on his FIRST DAY of work (LOTO)
OSHA has cited a bottling business with 12 alleged safety violations following the death of a 21-year-old temporary worker his first day on the job. He was crushed to death by a palletizer machine at the Jacksonville facility in August 2012. The company uses a temporary temporary staffing service to provide laborers for certain types of jobs. He was cleaning glass from under the hoist of a palletizing machine when an employee restarted the palletizer. The facility had failed to train temporary employees on utilizing locks and tags to prevent the accidental start-up of machines and to ensure its own employees utilized procedures to lock or tag out machines.
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