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You spend enough time working on Lockout/Tagout (LOTO) you are bound to come across some crazy situations. Luckily I have some world class clients who not only allow me to share my "interesting finds" but encourage me to share with all of you. This most recent find was at an OSHA VPP STAR site. We have been hired to do program specific audits each quarter, with an emphasis on energy control. This means even though I may be auditing flammable liquids this quarter, I am ALWAYS auditing LOTO and conducting "periodic inspections" (and yes I am an "authorized employee" within their LOTO program - I wrote it, wrote 99% of the machine specific control plans, and still do all the LOTO training at the facility). For the most part this facility KNOWS LOTO and LIVES IT DAILY; but we all have flaws - no one or no facility is perfect. Hence why we need LAYERS of PROTECTION in all our safety efforts. So today I was making my rounds talking with everyone and came across one of the safety committee members who was cleaning a piece of equipment. He knew I was there to do an audit, as he had participated in many audits with me before. He was PROUD and CONFIDENT of his ability to meet all LOTO requirements. But, the good will ended there. Here is the image of his electrical isolation - do you see anything wrong?
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.
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”.
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...
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:
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.