For those who manage Lockout-Tagout (LOTO) in a "processing operation" know first-hand how different LOTO is as compared to how its done in an "assembly line" style operation. I have always picked up some "Best Practices" for LOTO at the companies I worked for over the years and as a consultant, I have seen many more at some of my world-class clients. However, I have always struggled to put all of these best practices into one comprehensive document where they all work in concert with one another; that is until some of my international clients recently shared with me... Guideline Mechanical and Process Isolations Major Hazard Standard. This "guide", and yes it is NOT from OSHA or even a USA document, is without a doubt a MUST HAVE for any LOTO lover! Are you looking to take your LOTO program and practices to the next level; this guide will take you there. This guide even provides us with a very sound risk analysis on the different types of energy control methods based on the level of risk involved in the isolation - folks this is just AWESOME! For example, here is a means to semi-quantify the risks associated with tasks and the proper means of energy isolation for said risks... this is JUST PURE SAFETY CAKE:
In OSHA's LOTO standard (1910.147) the agency included in their definition of an "lockoout device" a "blank flange" and "bolted slip blind", when in fact these device are actually "energy isolation devices". So why would OSHA consider these devices a "lockout device"?
NOTE: I am not in agreement with this and have never called a "blank flange" and "bolted slip blind" a "lockout device", but rather energy isolation devices. This may seem like semantics, but it is HUGE in the world of energy control!
In the Final Rule, OSHA determined that lockout is a surer means of assuring deenergization of equipment than tagout, and that it is the preferred method. However, the Agency also recognized that tagout will nonetheless need to be used instead of lockout where the energy control device cannot accept a locking device. Where an energy control device has been designed to be "lockable", the standard REQUIRES that lockout be used unless tagout can be shown to provide "full employee protection," that is, protection equivalent to lockout. But what does OSHA consider to be "locakable"?
The Bureau of Safety and Environmental Enforcement (BSEE) has released the panel investigation report into the November 20, 2014 explosion and fatality on a platform. The explosion occurred on West Delta Block 105 Platform E, resulting in the tragic death of Jerrel Hancock. Mr. Hancock, a Turnkey Cleaning Services supervisor, died after an explosion occurred inside the electrostatic heater treater located on the platform while the contract cleaning crew personnel were engaged in activities related to cleaning the vessel. The five member investigation panel identified a number of failures in the application of basic safety management practices which may have contributed to Mr. Hancock’s death. The report concludes that there were apparent inadequacies in:
A 54 year old male employee was fatality injured while cleaning the de-stacker area of the mogul machine in the gummies department when he was crushed between a tray of product, and the frame of the de-stacker mechanism of the mogul machine. The mogul machine would become obstructed during the day with falling and shifting gummy trays, and starch. The track that moved the trays would get covered with these materials and would need to be cleaned with a pneumatic air wand. The victim performed the company lockout/tagout procedure for the mogul machine, and locked out the vertical movement of the de-stacker. As the victim entered the machine for cleaning, he inadvertently struck a positional sensor inside of the track system, and advanced the candy trays into the machine. The victim was standing directly adjacent to the metal frame of the de-stacker mechanism when a stack of trays began to advance into the machine, crushing him between a tray of product and the frame of the de-stacker.