So does every single energy isolation REQUIRE a written procedure/plan that identifies the types of energy, their magnitude, the means used to isolate them, and the means used to verify zero energy state (ZES)? YES... there is ONLY ONE (1) special exemption that excuses us from having a task specific isolation procedure/ plan and that exemption can be found in 1910/147(c)(4)(i). But before we get too excited about OSHA giving us a loophole to having a WRITTEN ISOLATION PLAN for every LOTO, we need to see the eight (8) criteria that OSHA has set forth for the "exception" to apply and I do think many will be sorely disappointed...
This week OSHA issued a willful violation for Lockout/Tagout (LOTO) deficiencies involving a spray dryer absorber (SDA) at a power generation plant. What is shocking is the fact that a 46 year old worker lost four (4) fingers on his right hand in the December 2015 accident and during the course of its investigation into the December 2015 accident, OSHA found that multi-finger amputations also occurred on this SAME SDA in August 2011 and October 2012. Folks this happened, not at a "mom and pop shop", but rather a power company with generating capacity of 26 GW, capable of supplying more than 21 million households, operates 35 Power Plants across 8 states, has 830,000 retail customers, residential customers and 23,000 commercial, industrial and municipal customers, and Annual Revenues of over $5 billion! (Source) And here we sit in 2016 not able to comply with one of the most fundamental OSHA standards that is now over 25 years old and three (3) workers have suffered debilitating - life changing injuries.
Here is a look at the citations:
This was a significant decision by the OSHRC as it answered the debate... do isolation plans associated with complex energy isolations need to include the means to verify Zero Energy State (ZES) for each isolated source? There answer... YES and it MUST be DOCUMENTED in the isolation plan/worksheet. The arguments the refinery put forth that the means to verify ZES was not required to be part of the written plan seemed only to annoy the ALJ. It all started in response to a fire in refinery’s crude oil unit, OSHA conducted an inspection of the Refinery on October 24, 2013. The fire broke out after hydrocarbons leaked into the air during the removal of a pump (line break/process opening) when a valve was not able to be closed 100% and was not recognized by the authorized employees. OSHA issued a citation alleging two serious violations and a proposed penalty of $14,000.00. Respondent withdrew its Notice of Contest as to Item 1 of the Citation. Thus, the only item under consideration is Citation 1, Item 2, and its associated penalty of $7,000.00. Respondent timely contested the Citation. The trial took place on April 29–30, 2015. Five witnesses testified at trial:
WARNING! This variance applies ONLY to Nucor Steel Connecticut Incorporated at its Wallingford, CT facility, as well as the SPECIFIC TASK listed, and can NOT be adopted by anyone else or any other workplace (NOT even another Nucor facility) in any fashion what so ever.
This information is being shared for INFORMATIONAL PURPOSES ONLY as OSHA is allowing the use of a "Trapped Key Safety System" in lieu of traditional LOTO practices. I am sharing this so that anyone interested in using this type of system in lieu of LOTO can see the process one must go through to get the VERY SPECIFIC variance and the extra's that OSHA requires under the variance. If it were me, I would have merely moved the energy isolation device (EID) from the Motor Control Room (MCR) to a location near the rolls so that traditional energy isolation methods could be utilized. This seems to be a lot of work for a single LOTO task that appears to have a much cheaper and easier solution. But here is the variance...
This incident is a PERFECT example of what can happen when STORED ENERGY is overlooked. For energy sources like hydraulics and pneumatic (e.g. gases), merely closing a valve and locking it closed or locking out a pump is NOT full energy control. Procedures MUST include the means to dissipate the stored energy to the Zero Energy State (ZES). Keeping in mind that sometimes the dissipation of this stored energy in and of itself can be a hazardous task and may require special PPE and procedures so as to not cause injury or create a hazard.