It’s easy to assume that machines are safe once they have been shut down. But that assumption often leads to tragedy. Here are some key aspects of OSHA’s lockout/tagout standard that can help safeguard your workforce
Veteran safety professionals know that simply turning off or unplugging a machine before maintenance, repairs, or retooling is not enough. Far too many serious injuries and fatalities occur because workers don’t realize that machines could contain residual energy or could start up unexpectedly.
National Institute for Occupational Safety and Health (NIOSH) investigations of 1,281 workplace fatalities between 1982 and 1997 found that 152 involved installation, maintenance, service, or repair tasks on or near machines, equipment, processes, or systems. Review of those cases identified three related factors that contributed to the fatalities:
- Failure to completely de-energize, isolate, block, and/or dissipate the energy source (82% of the incidents)
- Failure to lockout and tagout energy control devices and isolation points after de-energization (11%)
- Failure to verify that the energy source was de-energized before beginning work (7%)
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Measures to prevent such dangerous accidents in general industry are set forth in 29 CFR 1910.147 (Control of Hazardous Energy–more commonly referred to as “lockout/tagout”).
OSHA says that approximately 3 million workers service equipment and face the greatest risk of injury if lockout/tagout is not properly implemented, and that compliance with the lockout/tagout standard prevents an estimated 120 fatalities and 50,000 injuries each year.
The standard requires employers to establish a comprehensive written procedure for the complete shutdown of any source of power that could otherwise reach a machine or other piece of equipment being worked on. The employer must also communicate the importance of the lockout program to all workers who might be at any risk and provide training for all “affected” and “authorized” employees.
An affected employee is one whose job requires him or her to “operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout” or to “work in an area in which such servicing or maintenance is being performed.”
An authorized employee is the person who locks out or tags out a machine or other piece of equipment in order to perform servicing or maintenance on it.
Our sister publication, the twice-monthly OSHA Compliance Advisor, notes that although the standard allows the use of tags in addition to locks, it specifies that they not be used instead unless “the employer can demonstrate that the utilization of a tagout system will provide full employee protection” or “that the energy isolating device is not capable of being locked out.”
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Lockout and tagout devices must be the only devices used for controlling energy and must not be used for other purposes. They must also be:
- Durable–able to withstand the environment to which they are exposed
- Standardized–within the facility in one or more such ways as color, shape, or size (plus print and format for tags)
- Identifiable–indicate the employee who applied the device
The employer must conduct and certify, at least annually, inspection of the energy control procedure to “ensure that it and the requirements of the standard are being followed.”
A Few No-Nos
Ignoring or deviating from the precise prescribed lockout procedures can have devastating results for oneself and co-workers. So an authorized employee must NEVER:
- Assume that locking out the control circuit, but not the main disconnect or switch is good enough. Even a drop of water or some dust particles can cause a machine to start on its own.
- Leave his or her key in the lock so as not to lose it–this can destroy the intended protection.
- Give his or her lock to a co-worker to perform the shut-off and lockout.
The Training Task
The employer must provide training to ensure that workers understand the purpose and function of the energy control program and have the knowledge and skills required for the safe application, use, and removal of the controls. Retraining of authorized and affected employees must be provided (and documented) whenever there is a change in:
- Their job assignments
- Machines, equipment, or processes that present a new hazard
- The energy control procedures
In tomorrow’s Advisor, we’ll look at the training requirements of the lockout/tagout standard, and at a tool that dramatically drives home the critical importance of lockout/tagout procedures.