- program
- procedure
- Recommended course of action
- Devices
- Training
- annual accounts
Such a broad and specific question at the same time, isn't it?
Lockout-Tagout is the shutting down and protection of equipment, machinery or processes so that hazardous energy is not reintroduced during maintenance or repair. These include closing circuits and valves, countering temperature extremes, protecting moving parts, and more.
But security professionals know that this simple lock-and-tag definition only scratches the surface.
A brief history of LOTO
The OSHA Hazardous Energy Control Lockout/Tagout Standard, Title 29 Code of Federal Regulations (CFR) Part 1910.147, was developed in 1982 by the United States Occupational Safety and Health Administration (OSHA) to provide protection for Assist workers in routine maintenance of equipment on site. It came into legal force in 1989. Since then, the lockout norm has played a crucial role in keeping employees safe in the workplace. Key lock statistics show that lock programs:
- Save lives by preventing an estimated 50,000 lockout tagout injuries and 120 deaths each year[1]
- Reduce costs by reducing lost employee time and insurance costs
- Improve productivity by reducing equipment downtime
OSHA provides tips and resources on workplace lockouts and safety requirements, including aoverviewedata sheet.
What is the difference between Lockout and Tagout?
Although often confused, the terms "blocking" and "signalling" are not interchangeable.
Block
BlockOccurs when a source of energy (electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other) is physically separate from the system that uses it (machine, equipment, or process). This happens with a variety ofpadlocks and locking devicesbest suited for certain applications. devices likebreaker locksorvalve blockagescan be used for more specific locking tasks.
day out
day outis the process of applying a label, ormark, which provides information about what is being done on the machine or equipment and why it is important. Details about a tag can include:
- DANGER orNOTICE Lockout Sign
- Instructions (e.g. do not operate)
- Purpose (e.g. device maintenance)
- Timed coordination
- Name and/or photo of authorized employee
Tagging alone is not recommended as it provides no physical way to prevent the device from being powered back on. Since the lockout and tagout standard began in 1989, power isolation points have been modified or replaced to accommodate thissafety padlockplacement, and new devices have been developed to adjust power sources to help meet the standard.
When used together by attaching a tag to a padlock, the lock and tag provide improved protection for workers from being switched on again.
Components and Considerations of Lockout and Tagout Programs
Elements and Compliance
A typical locking program can contain over 80 separate elements. have oneOSHA Compliant Lockout Signaling ProgramThey must contain:
- Locking and tagging standards, including creating, maintaining, and updating device lists and hierarchies
- Task Specific Procedures
- workplace regulations, such as B. Confined space access requirements
Best practices for blocking and tagging
Periodic inspections are required. As a best practice, an annual review of revocation procedures is recommended. Other best practices include:
- program standardization
- Lockout and tagging software
- Authorized/affected annual training (authorized more frequently)
- Update isolation points
- change management
- contractor training
- device inventory
Coordination with local contractors
The host employer is often more familiar with the flow control procedures used at the host facility. However, per 29 CFR §1910.147(f)(2)(i), host and contract employers are required to inform each other of their respective performance review procedures.[2]Such coordination is necessary to ensure that both groups of employees are protected from hazardous energy.
Contractor shall take reasonable blocking and tagging measures within its authority to protect its employees if Contractor knows or has reason to believe that the Host's power control procedures are inadequate or inadequate to provide the protection required by your employees.
Written procedures for powerlifting gear and docks
In standard shipping and receiving areas or docks, you will need machine-specific written procedures for:
- dock levellers and locks
- battery chargers
- Palettierer
- cranes
- cranes
- Anything connected to a panel
Building and farming - separate but similar
Construction has its own set of rules and is therefore not covered by the industry. Agriculture CFR 1928 makes no mention of lockout tagout, but the NIOSH-supported National Ag Safety Database includes recommendations for lockout programs. All steps follow OSHA 1910.147.
If you are implementing an agricultural program, look at all of the equipment in the facility and identify isolation points for each equipment. Create procedures and purchase locks, devices, and tags to isolate devices during maintenance. Train your authorized personnel on when, how and why to lock down during device maintenance.
1910.147 Ancillary Service Clause
OSHA has additional guidance on thesmall service clause, which is an exception to the lockout tagout pattern. Three specific criteria must be met for this clause to apply:
- Occur during normal production operations
- Be routine, repetitive, and integral
- Use alternative measures to ensure effective protection against hazardous energy
Paperwork requirements for group, complex, or concurrent operations
Paperwork tag blocking requirements vary by company. However, a best practice is to record all services that require locking with signature sheets of all isolation devices. Any permits required to perform the service (hot work, confined space, or work at height) must be copied and retained with the service record. Keeping devices and documentation together is a best practice, usually achieved through the use of aAllow control station.
Understand the requirements for lockout and tagout procedures
Group similar machines together
OSHA allows the same or similar devices and processes to be grouped together to reduce the burden of periodic inspections. A good practice is to post a specific procedure for each individual machine on or near the machine. Even if you have two identical machines, it's still preferable to have one procedure for both. This will help avoid confusion and show inspectors your thoroughness.
Some companies develop generic drugsLockout and tagging proceduresand supplement them with checklists or appendices to cover many different pieces of gear as part of your lockout system. This type of procedure can be considered a single power control procedure (rather than multiple procedures) for inspection purposes if all criteria for grouping like or similar devices are met. However, if the checklists or annexes relate to equipment that does not all use the same or similar types of control measures, the employer is required to classify the machines and equipment into groups based on the same or similar types of control measures.
Once this is done, the employer can review and revise the generic energy control procedure associated with each individual group of equipment referenced in the relevant checklists or annexes.
Machine-specific locking procedures for contract workers
You need machine-specific procedures for all equipment in your facility, even if contractors are the only people authorized to work on the equipment. In addition, all staff must be trained, even where there are no authorized staff, and a regular (best practice: annual) review of the procedure must be conducted, with any changes communicated to contractors prior to maintenance.
Devices exempt from lockdown procedures
To be exempt, devices must meet all eight criteria of 1910.147(c)(4)(i):[2]
- No stored or residual energy
- Easily identifiable and isolable single source
- The single isolation point must be de-energized to the de-energized state
- This point is blocked
- single locking
- Exclusive control by authorized employees
- No danger for affected employees
- No equipment accidents
Devices with a single power source are excluded
Typically this is any plug and play device such as laptops, office equipment, fans, power tools, portable devices and anything that can be plugged in and easily isolated with a single power cord or disconnect point. The signal barring must still be followed, but you don't need a written procedure.
Procedures Written by Contractor
Authorized contractors can write machine-specific procedures, although these procedures are best developed by personnel familiar with the installation to ensure the correct disconnect switch is used. Outside contractors unfamiliar with the equipment could lose a power source if authorized personnel are not involved in verifying that the processes reach a zero-current condition.
Exceptions and best practices for lockout and tagout applications
Temporary removal of the locking or signaling device
Exceptions where a zero power state cannot be achieved due to the task at hand are covered by OSHA 1910.147(f)(1).[2]When testing or positioning equipment requires temporarily removing lockout or tagging devices from the energy isolating device and turning on the equipment, the following lockout and tagging steps must be followed:
- Clean the machine or equipment of tools and materials in accordance with paragraph (f)(1)(i) of this section
- Remove personnel from the machine or equipment area in accordance with paragraph (f)(1)(ii) of this section
- Remove any locking or marking devices as specified in paragraph (f)(1)(iii) of this section
- Power on and continue testing or placing (f)(1)(iv)
- De-energize all systems and reapply performance control measures in accordance with paragraph (f)(1)(v) of this section to continue service and/or maintenance
Shift changes and personnel changes
In general, delegation of responsibility can be achieved by the front-end taking control of a system before the field workers relinquish control of that system. The orderly handover of personal locking and tagging devices between exiting and entering employees should ensure that there is no gap in coverage between the removal of locking devices by exiting employees and the attachment of devices by entering employees.
Do not replace employees with devices during an active lockdown
The OSHA standard states that only mechanical devices and tags should be used. For example, an authorized employee is not allowed to monitor a replacement device instead of a device while another authorized employee is servicing the device. While practical, OSHA specifically states that such a method is not as reliable as a mechanical device.
Checking a zero power condition
It is recommended that electrical components be tested with a meter to check insulation if panel testing is not possible. There are several ways to verify that the pressure has been released. Noise is a common practice in compressed air lines because exhaust valves make a loud noise when pressure is released. Depending on the location of the disconnect point, connecting pneumatic tools to the line to flush the line is another way to verify the absence of voltage.
Lock device computer
Estimate the number of devices needed per installation
The total number of lockout devices required for your lockout and tagout system varies by organization. Here's how to get a good estimate for your organization:
- Decide how many stations or departments will need an enclosure or interlock board.
- Discuss with authorized personnel where the cabinet or panel should be located depending on the location of the equipment, with high traffic equipment areas being the primary factor in the placement of lockout and tagout stations.
- Look at areas with high-risk equipment (boilers, chillers, generators, and gear rooms) and production departments. Count the total number of devices required for all type-specific written procedures in the desired area and order 10% of the total number of devices. If the boiler room has 50 fittings and 100 ball valve devices, the boiler shut-off station must have 10 ball valve devices. The need to lock down all devices on your premises should never happen, but an initial order of 10% is a good place to start.
- Monitor Lockstation devices with an inventory to see if additional devices need to be ordered after the initial order.
Lock training requests
Sufficient practical training materials
Sufficient lockout training documentation requires the authorized employee to sign that the trainee fully understands the lockout signaling equipment and program.
Frequency of blocking and signaling training
They should conduct lockout training for employees when they are hired and they should be retrained when there is a gap in behavior, knowledge or changes in procedures. While not mandatory, it is good practice to provide training during the annual equipment overhaul.
Brady offers a lockCurso Train-the-Trainer, as well as additional lockout and tagout training opportunities.
Contractor lockout training requirements
Lockout training includes contractors. Any contractor authorized to service equipment must meet the requirements of the lockout program and be trained on the program's written procedures. Depending on your written program, contractors may need to do a group lockdown with an authorized employee.
Contractor lockout training responsibilities
The responsibility is shared. The host employer is generally most familiar with the flow control procedures used in the host facility; However, the standard requires host and contract employers to learn about their respective energy control procedures. Such coordination is necessary to ensure that both groups of employees are protected from hazardous energy.
Annual lock and tag audits
requirements
Annual recurring inspections must be performed by an "authorized officer" and must include at least two components:
- An inspection of each power control process
- A review of the responsibilities of each employee as part of the energy control process to be inspected
Documentation
Employers must certify pursuant to §1910.147(c)(6)(ii)[2]that the required periodic inspections have been carried out. The certificate must contain the following:
- The machine or equipment on which the power control method was used
- The inspection date
- The names of the employees involved in the inspection
- Name(s) of person(s) who carried out the inspection
Review x Audit x Inspektion
Annual review, audit and inspection relate to the same lock and tag requirement. They can occur at any time throughout the year.
Second person verification
A second person to inspect the equipment must be authorized and ensure that all personnel servicing this equipment are well informed of the procedure and responsibilities. A second person must also document this inspection.
Machine inspections vs. groupings
In general, annual inspections must be carried out for every machine. However, OSHA allows an employer to combine separate machine-specific lockout and tagout procedures into one procedure to comply with the lockout and tagout standard, provided the machines or equipment in the group have the same types of control measures. Power control methods that are used less than once a year only need to be checked if they are used.
Authorized Employee Participation Requirements
The lockout and tagout standard requires that a procedure to be inspected be reviewed as part of the periodic inspection (1910.147(c)(6)(i)(C)) with all authorized personnel.
Degree of formality and scope
In order to meet the verification requirement, the verifier does not have to observe all authorized personnel performing the power verification procedure on the devices they service/maintain. Instead, the auditor conducting the inspection may observe and speak to a representative number of personnel conducting the procedure to get a fair representation of the service/maintenance practices being assessed.
In addition to this representative sampling approach, further analysis needs to be carried out with all authorized personnel who are expected to carry out the procedure during the year. Group meetings can be the most effective way to meet review requirements and restore employee accountability and authority.
references
- OSHA Data Sheet - Lockout Tagout. Retrieved October 5, 2021 from https://www.osha.gov/sites/default/files/publications/factsheet-lockout-tagout.pdf.
- 1910.147 - Control of Hazardous Energy (Lockout/Tagout). Occupational Safety and Health Authority. (n.d.). Retrieved October 7, 2021 from https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147.
Product Recommendations
Here are our top product recommendations to get you started.
Electric locking devices
block tags
Block padlocks
blocking signals
hose and valve blocking devices
Link360 security software
resources
Learn more about complying with Lockout Tagout in The Safety Professionals Expanded Guide to LOCKOUT TAGOUT
Download
Learn what equipment you need to effectively use Lockout and Tagout in your facility with our downloadable checklist.
Download
Learn the 6 Elements of an OSHA Compliant Lockout Signaling Program.
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