Here is a look at OSHA's Lockout/Tagout (LOTO) activity in 2016 (October 2015 - September 2016). As you can see, OSHA did 1,780 LOTO inspections (↓) and issued 3,235 citations (↑) for a total of $16,611,253 in fines (↑). 2015 numbers were 1,796 LOTO inpsections; 3,139 citations; and $9,013,808.

This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:

  • NAICS Code: 332 Fabricated Metal Product Manufacturing was #1 in # of citations with 496
  • NAICS Code: 336 / Transportation Equipment Manufacturing was #1 in $'s with $5,934,673
  • NAICS Code: 332 Fabricated Metal Product Manufacturing was #1 in # of inspections with 290

emphasis added by me and professionally speaking, this LOI is just "crazy talk" and why OSHA LOTO minimums should be viewed as just that... the ABSOLUTE MINIMUM!  In this LOI, OSHA has established that using a "zip-tie" in the manner in which you would apply a lockout lock to an electrical disconnect would meet the "tag-plus" requirement under a "tag-out" program!  So basically, if you were to hang a Tagout tag with a zip tie and run the zip tie through the disconnect handle so that the handle is secured in the OPEN/OFF position, this would suffice in meeting the "additional means" requirement under the tagout provisions.  So today class, we have learned from OSHA that a zip tie is equal to a lock - NOT!, NO WAY!, NEVER!  I swear in Question #2 that OSHA is accepting the mere placing of a zip tie on the "closed electrical panel box after placing the control switch in the off position and performing verification" as an "additional means of demonstrating full employee protection under the standard".  So the zip-tie is merely hanging a tagout tag from the box/cover and is not even through the handle and this meets compliance?!?!?!  But again, meeting OSHA minimum in a life-critical procedure is NEVER a good idea!  Here's the scenario and questions with OSHA's response...  you may want to sit down before reading further!

Scenario: Maintenance and servicing activities are required and the plant owner hires a contractor to perform the work using ONLY a tagout program, although the devices ARE CAPABLE of being locked out. The electrical disconnect (i.e. control switch) [SAFTENG comment - the disconnect is the ISOLATION DEVICE - NOT a control device] is placed in the OPEN/OFF position, verification is performed, and the panel is closed and secured with a plastic zip tie at the point where a lock would be used. This is all done by a plant representative. At this point, the plant considers the equipment safe for contractors to sign onto the plant's clearance and to begin maintenance or servicing activities.

With last weeks tragic accident in my old stomping grounds of DeRidder, LA I am reminded of OSHA's laguage in 1910.252.  I know of no other standard that has such "matter of fact" style language.  In the standard, OSHA uses the phrase "absolutely certain" in regards to ensuring the "container" is gas/vapor free. In fact the standard goes as far as requiring the "container" be free of "any substances such as grease, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors".   In a paper mill a "foul codensate" tank fits these definitions darn near perfectly.  We will have to wait until all the investigations are completed to know more, but in reality WELDING ON CONTAINERS has some ABSOLUTE REQUIREMENTS for a good reason.  May the three contractors who died in this accident Rest In Peace and may God be with their loved ones. 

 

1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers until they have been cleaned so thoroughly as to make absolutely certain that there are no flammable materials present or any substances such as greases, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors. Any pipe lines or connections to the drum or vessel shall be disconnected or blanked.

 

Inspections
New Inspections 4,858
Closed Inspections 5,026
Inspections With Violations 65
Inspections With No Violations 4,793
Current Penalties $397,508.50
Inspection Types
Inspection Type Accident 143
Inspection Type Complaint 1,124
Inspection Type Referral 683
Inspection Type Followup 193
Inspection Type Unprog Related 198
Inspection Type Planned 2,120
Inspection Type Other 286
Violations
Serious Violations 2,057
Willful Violations 9
Repeat Violations 124
Other Violations 414
OSHA Top 10 NAICS Codes
238160: Roofing Contractors 303
238130: Framing Contractors 272
236220: Commercial and Institutional Building Construction 259
238140: Masonry Contractors 118
238220: Plumbing, Heating, and Air-Conditioning Contractors 102
236115: New Single-Family Housing Construction (except Operative Builders) 99
238210: Electrical Contractors 91
237310: Highway, Street, and Bridge Construction 78
238990: All Other Specialty Trade Contractors 58
237110: Water and Sewer Line and Related Structures Construction 58

February 1st is just around the corner and this is a reminder for those of you who maintain OSHA 300 Log(s) that it is time to:

One of the questions I get often is "What if an OSHA standard says one thing and my fire code says something else?" First, let me say I am so pleased when I get this question as it means there's a business utilizing the fire code; as so many do not even know it exist. But to answer the question, OSHA standards rule the rooster in most states (notice I said "most"). For example, in the state of Ohio the revised code states:

 
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