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Teach Locks - Tags Audit
LOCK OUT / TAG OUT
Shannon LozeauMS, CIH, CSP, TURP
ECO DEVENS ROUND TABLE
April 2018
Teach Locks - Tags Audit
OSHA’s Top 10 List (9/2017)
Standard Number of citations
1. Fall Protection – General requirements (1926.501) 6,072
2. Hazard communication (1910.1200) 4,176
3. Scaffolding (1926.451) 3,288
4. Respiratory protection (1910.134) 3,097
5. Lockout/tagout (1910.147) 2,877
6. Ladders (1926.1053) 2,241
7. Powered industrial trucks (1910.178) 2,162
8. Machine guarding (1910.212) 1,933
9. Fall protection – Training requirements (1926.503) 1,523
10. Electrical – Wiring methods (1910.305) 1,405
Teach Locks - Tags Audit
LOTO Basics
• 29 CFR 1910.147
• Purpose
• Exemptions
• Application
• Affected Employee
• Authorized Employee
• Energy Sources• Electrical,
• Mechanical,
• Hydraulic,
• Pneumatic,
• Chemical,
• Thermal, or
• Other energy
Teach Locks - Tags Audit
Education – Who…What
Affected
• Purpose for the procedures being used
Authorized
• Recognition of hazardous energy
• Type/magnitude of energy in workplace
• Means/methods of isolating/ controlling energy
• Means to verify effectiveness of energy controls
• Purpose for the procedures being used
Others
• Told of procedure and prohibition related to attempting to restart equipment that is LOTO.
Teach Locks - Tags Audit
Education - When
Initially, or prior to performing service or maintenance
Retraining is required if:• Change in job assignments• Change in machines• Change in energy control procedures• Equipment or processes present new hazards• Inspections reveal deficiencies in employee's
knowledge of energy control procedures• Retraining must reestablish employee proficiency
Teach Locks - Tags Audit
Application of the Energy Control Procedure
1. Prepare for shutdown
2. Shut down equipment
3. Isolate all energy sources
4. Apply locks & tags
5. Release stored energy
6. Verify equipment isolation
7. Perform the task
8. Release from Lockout
Notify Shutdown
Isolate Attach
Release Verify
Service Release
Teach Locks - Tags Audit
My ProgramDefining the Expectation
Teach Locks - Tags Audit
Written Program
My written program outline
Teach Locks - Tags Audit
Consistency? What’s the message?
Teach Locks - Tags Audit
My Summary Sheet
Teach Locks - Tags Audit
Key Control???
How many people have the key to that lock?
Where is the “single key” kept?
Do you have all the extra keys that came with the locks?
Do people know where you keep them?
Teach Locks - Tags Audit
My Equipment ListIdentifying the Equipment and Why LOTO applies or not
Teach Locks - Tags Audit
8 Point Exclusion
1. No stored energy
2. Single energy source
3. Isolation completely deenergized
4. Completely isolated
5. (1) LOTO device
6. LOTO devise exclusive control
7. No hazard to others
8. No accidents
Teach Locks - Tags Audit
My Equipment List
Teach Locks - Tags Audit
Equipment Specific ProcedureSpecific Procedures - Many ways to accomplish this!
Teach Locks - Tags Audit
Energy Control Procedures
• Must be specific to each type of machine and equipment you are working on
• Must include – Statement of intended use
of the procedure – Steps for shutting down and
securing machines and equipment
– Steps for placing, removing, and transferring of lockout devices
– Requirements for testing and verifying effectiveness of lockout devices
1. Energy Types2. Shut down3. Isolation4. LOTO
application5. Release6. Verified OK
Teach Locks - Tags Audit
My Current Procedures
Teach Locks - Tags Audit
My Next Version of Procedures
Teach Locks - Tags Audit
My Next Version of Procedures cont’d
Teach Locks - Tags Audit
AuditingEnsuring your folks are applying the program as you intended.
Teach Locks - Tags Audit
Periodic Inspections
• Performed at least annually
• Conducted by authorized employees
• Intended to correct inadequacies identified in program
• Certified
Teach Locks - Tags Audit
Certification Requirements
• Identification of equipment or machinery
• Date of inspection
• Names of employees involved in the inspection
• Name of person(s) performing inspection
Teach Locks - Tags Audit
Periodic Inspection Form
Simple Detailed
Teach Locks - Tags Audit
Some Field Audit ExperiencesAuditing the program YOU created….
Teach Locks - Tags Audit
Auditing the Program
ProtocolSectionQuestion# Question QuestionRefs Reference
Lockout/Tagout 1Does the site have a written hazardous energy control program?
The following elements should be included in the program: General Energy control procedures; Equipment specific procedures for multiple energy sources; Protective materials and hardware; Periodic inspections of procedures; Employee training; Application o
Ref: 29 CFR 1910.147(c)(1); EHS Standard ### Control of Hazardous Energy - Section 2.2 a through f
Lockout/Tagout 2
Are written energy control procedures available for each piece of equipment that does not meet all 8 exceptions listed in OSHA 1910.147(c)? OSHA 1910.147 (c)(4)(i) - Exception: The employer need not document the required procedurefor a particular machi
Procedures must include: Scope and purpose; Specific procedural steps for placement removal and transfer of lockout devices and the responsibility for them. Specific procedural steps for shutting down, isolating, blocking, and securing hazardous energy;
Ref: 29 CFR 1910.147(c)(4); EHS Standard ### Control of Hazardous Energy - Section 2.2
Lockout/Tagout 3Has each energy control procedure been reviewed annually by an authorized employee?
There are special situations to recognize with this issue. Energy control procedures used less than once per year need be inspected only prior to use. Similar machines and/or equipment (e.g., those using the same type and magnitude energy) which have th
Ref: 29 CFR 1910.147(c)(6); EHS Standard ### Control of Hazardous Energy - Section 2.2
Lockout/Tagout 4Has adequate initial training and retraining been conducted for authorized, and affected employees?
Review training material and records. Interview several employees during the site walk-through. Content of the authorized employee training program: Recognition of applicable hazardous energy sources; Type and magnitude of the energies in work area; Met
Ref: 29 CFR 1910.147(c)(7); EHS Standard ### Control of Hazardous Energy - Section 2.6
Lockout/Tagout 5
Do observations made during the site walk-through confirm that the hazardous energy control program has been implemented and is effective?
Verify that locks and tags specified for lockout/tagout use by the site hazardous energy control program are being used as required, and solely for lockout/tagout purposes. Ensure that employees know where to obtain procedures and equipment and can ident
Ref: 29 CFR 1910.147; EHS Standard ### Control of Hazardous Energy -Section 2.5 b and c
Lockout/Tagout 6
Does the hazardous energy control program include provisions for coordinating with outside contractors and is the method of coordination being utilized and effective?
Verify that lockout/tagout is a specific requirement within the site’s contractor safety program and that it addresses the use of energy control procedures. Ref: 29 CFR 1910.147(f)(2)
Teach Locks - Tags Audit
Auditing the Program
Consider putting a “periodic inspectioncertification” statement on your LOTOEquipment Specific Procedure and havingpeople complete the form every time theydo the LOTO on that equipment. Probablybetter way to go for infrequent LOTO uses.
Teach Locks - Tags Audit
Some Field Audit ExperiencesWhat’s happening in the “Real World”?
Teach Locks - Tags Audit
Injuries Still Happening !!!!!!
• Worker inside kiln died when automated system locked and activated it (4/2017)
• Conveyor Belt breaks bones in worker’s hand and arm: $140K OSHA fine (12/16/15).. Wegmans Food Market Bakery. 3rd fine in 5 years.
• a sanitation crew member losing his fingertip when it caught in the pinch point of an operating conveyor he was cleaning, and
• a mechanic suffering a first-degree burn on his wrist when steam released while he attempted to repair a valve.
• Tootsie Roll temp loses part of finger: $55k OSHA fine (2/2/16 Cambridge, MA)
• Machinery Hazards: $88k OSHA fines (12/2015- GE)
Teach Locks - Tags Audit
LOTO done wrong…..
From OSHA LOTO training
Unjamming a printing press without de-energizing it
Troubleshooting
Teach Locks - Tags Audit
LOTO done wrong…..
Employee servicing printing press without de-energizing equipment Employee trying to adjust
machine when runningFrom OSHA LOTO training
Teach Locks - Tags Audit
LOTO done wrong…..
From OSHA LOTO training
Teach Locks - Tags Audit
LOTO done wrong…..
Teach Locks - Tags Audit
LOTO done wrong…..
Teach Locks - Tags Audit
LOTO done wrong…..
Teach Locks - Tags Audit
LOTO done wrong…..
Teach Locks - Tags Audit
LOTO done better…..
Teach Locks - Tags Audit
AllegedlyReal Photos
Teach Locks - Tags Audit
Let’s talk turkey….
• Do you have a LOTO program?• Do you have equipment specific
procedures?• Do you train…different levels, but nearly
everybody at the end of the day.• Do you do periodic inspections?
Correctly?
• Where do you find your challenge? • Any lessons learned to share?