The state of NC has its own OSHA Plan (e.g. State Plan) but they use the Federal OSHA standards as their enforcement tools.  As like most state plans, their website is a buffet of safety materials that are free for the taking.  In fact, I used some of their materials when I was a safety manager in industry years ago.  But recently I was truly let down by NC-OSHA!  I was doing a PSM/RMP audit at a facility and we were reviewing their energy control program (e.g. LOTO) and I took issue with the fact that the facility had not identified their Lockout Locks by either a COLOR, SHAPE, or SIZE as required by 1910.147(c)(5)(ii)(B).  They were using a hodge-podge of locks of all different shapes, sizes, and colors and had merely used a label maker to label each Lockout lock with the words "Lockout Lock".  The labels were yellow with black font.  Granted, interviews indicated that everyone could identify the facility Lockout Locks, but this was because each lock had the words "Lockout Lock" on it.  I did find some workers using the same brand, size, and color locks on some jobs AND THEY DID NOT HAVE THE YELLOW LABELS on them so I wrote a finding against their program/practice and referenced 1910.147(c)(5)(ii)(B)...

Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized.

Only to have this sent to me today in rebuttal of my finding...  (hard to argue the site did anything wrong when they have this supporting documentation from NC-OSHA)

A 51-year-old female employee was fatally injured when she leaned into a machine and was pinned, resulting in crushing injuries to her head and neck. On the day of the incident, the victim was helping out on windshield #1 line due to low staffing levels resulting from inclement weather. She was to keep the line running and relieve other employees so they could go on break. The victim noticed the video ink jet on #1 line was not printing correctly on the windshields. She notified the supervisor who then left the area to begin the process of stopping the line so the ink jet could be repaired. When the supervisor came back to windshield #1 line, she found the victim, with her head and neck pinned between the automatically actuated carriage that carries the windshield to the ink jet, and a fixed metal portion of the machine. The investigation determined that the machine was not properly guarded to prevent physical entry into the machine while in operation, and the machine was not locked out prior to the victim
entering the area which allowed the machine to actuate. 

  1. What is OSHA's LOTO documentation requirements?

  2. Did you see the "tagout" in CSB's latest Bulletin?

  3. Did the OSHRC just say that 1910.147 Appendix A without any revisions is an acceptable "machine specific" LOTO procedure?

  4. OSHA issues REPEAT LOTO & Guarding Citations ($503,380)

  5. LOTO in 2017 has got to be better!

  6. OSHA issues LOTO citations regarding a ribbon blender fatality

  7. Here's a LOTO scenario many don't think about (Lock removal & $17K)

  8. LOTO Fatality - 38-year old welder was fatally injured while doing maintenance on a large chip conveyor (WA-OSHA Video)

  9. The classic LOTO fatality still occurs!

  10. Guide for the Control of Hazardous Energy in the Process Industries (MIRM)

  11. Why does OSHA consider a "blank flange" and "bolted slip blind" as a Lockout device?

  12. When is an "energy isolation device" "capable of being locked out"

  13. BSEE Releases Investigation Report into Platform Explosion (LOTO error)

  14. Crushed by and caught-in between machinery (TN-OSHA Inspection #1041324)

  15. Caught in Auger Fatality (TN-OSHA Inspection #1040935)

  16. Did you know... almost every single energy isolation REQUIRES a WRITTEN ENERGY ISOLATION PLAN

  17. For goodness sake - LOCK IT OUT people! (Willful w/ $70K)

  18. Even in "complex energy isolations" we MUST include specific procedures to VERIFY ZERO ENERGY of EACH isolation point (OSHRC)

  19. OSHA grants permanent LOTO variance

  20. Workers hurt when pressurized fluid escapes (LOTO Incident @ Mine)2015 OSHA LOTO activity by Industry Sectors

  21. OR-OSHA publishes "Oregon OSHA’s guide to controlling hazardous energy"
  22. ZERO energy state (ZES) means ZERO energy state
  23. LOTO Accident Data from OSHA's Preamble
  24. More LOTO Adventures
  25. MIOSHA Guidance: Minor Tool Changes and Adjustments, and Other Minor Servicing Activities
  26. LOTO and Contractors
  27. Lockout is the RULE, “minor servicing” is the exception
  28. It is Lockout OR tagout... NOT BOTH
  29. LOCKOUT/TAGOUT Methods and Sample Procedures (CAL-OSHA)
  30. Why does OSHA permit the LOTO exception ONLY on electrical cord and plug equipment?
  31. OSHA's requirement for "machine specific" LOTO procedures and the "exception"
  32. LOTO fatality while cleaning (NY FACE)
  33. From a recent OSHA citation for LOTO, yes we still have problems!
  34. LOTO Fatality - Caught in conveyor system (TN-OSHA II #28 - 2010)
  35. A traditional LOTO fatality - worker started equipment on another worker (TN-OSHA #23)
  36. Clearing up a couple of LOTO myths
  37. Palletizer kills temporary worker, 21, on his FIRST DAY of work (LOTO)
  38. OSHA takes issue with EVERY Authorized Employee having a key to the lockbox
  39. Have you ever seen/heard of this LOTO practice before?
  40. LOTO Periodic Inspections and their significance
  41. LOTO Program Suggestions from a reliable source!
  42. OSHA cites manufacturing plant for exposing workers to hazardous energy sources during machine servicing
  43. LOCK IT OUT!!! WARNING - Image may be upsetting to some
  44. Is tagging a blind flange or slip blind "tagout"?
  45. De-enerizing Stored Energies
  46. Verifying the content of lockout programs
  47. Supervision in Manufacturing - Guards & Lockout (Video)
  48. Defining Exclusive Control under LOTO activities
  49. Minor Servicing Alternative Safety Measures
  50. OSHA, LOTO and the unexpected movement of trucks
  51. Proper LOTO or a serious problem? (POLL)
  52. Verifying ZES is DIFFERENT for electrical workers!
  53. My TOP 12 Life Saving LOTO Principles
  54. Group LOTO Verification of ZES Requirements
  55. Periodic Inspections
  56. LOTO Training Requirements
  57. Shift or Personnel Changes
  58. Verification of ZERO ENERGY STATE (ZES)
  59. Tagout and Full Employee Protection (e.g. Tag Plus)
  60. Can ALL your LOTO Training needs be met by On-Line Training?
  61. LOTO on Chemical Process and Piping Systems
  62. Does your LOTO program contain "enforcement" procedures?
  63. GREAT LOTO Cartoon (VIDEO)
  64. Lock out. It takes just seconds to lose a limb (VIDEO)
  65. One of my favorite LOTO videos (VIDEO)
  66. FALSE Sense of Safety...using interlocks in Lieu of LOTO!!!
  67. We have THREE Choices to Identify our Lockout Locks
  68. Tagout vs. Lockout
  69. Company argues before the OSHRC that LOTO does not apply to their die changing activities - an analysis of a OSHRC 2009 decision
  70. Cord and Plug Equipment and "Line of Sight"
  71. Tagout vs. Lockout #2
  72. 911 Call - What REAL TRAGEDY sounds like (911 audio)
  73. Grouping equipment for purposes of conducting periodic LOTO inspections     
  74. LOTO Machine Specific Procedures

The standard specifies several information collection requirements. The following sections describe who uses the information collected under each requirement, as well as how they use it. The purpose of these requirements is to control the release of hazardous energy while workers service, maintain, or repair machines or equipment when activation, startup, or release of energy from an energy source is possible; proper control of hazardous energy prevent death or serious injury among these workers.

Energy Control Procedure (paragraph (c)(4)(i))

With limited exception, employers must document the procedures used to isolate from its energy source and render inoperative, any machine or equipment prior to servicing, maintenance, or repair by workers. These procedures are necessary when activation, start up, or release of stored energy from the energy source is possible, and such release could cause injury to the workers.

Paragraph (c)(4)(ii) states that the required documentation must clearly and specifically outline the scope, purpose, authorization, rules, and techniques workers are to use to control hazardous energy, and the means to enforce compliance. The document must include at least the following elements:

CSB TagoutThe US Chemical Safety Board's (CSB) most recent Safety Bulletin : Key Lessons from the ExxonMobil Baton Rouge Refinery Isobutane Release and Fire was once again a great piece of work by the agency.  But as with most incidents, there are always other underlying issues that may have contributed (or not) to the incident.  In this bulletin, I could not help but notice a very poor practice as shown in one of the bulletin photos. Do you see it?  SAFTENG members can see the answer below

The OSHRC sided with the company which had used Appendix A from 1910.147 as their machine specific LOTO procedure.  They did so without any revisions to the content of the Appendix and the OSHRC found this as an acceptable machine specific LOTO procedure!   

 
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