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D.SRINIVASULUAndhra Pradesh. Phone: +91-9985338435, +91-9849062145
INDIA. E-mail: [email protected]
OBJECTIVE:
Intend to build a career with leading corporate of hi-tech environment withcommitted and dedicated people, which will help me to explore myself fully and
realize my potential. And willing to work as a key player in challenging and creative
environment to reach higher positions by being resourceful, innovative and flexible.
ACADEMIC PROFILE:
M.SC Chemistry from Nagarjuna University in 2011
P.G Dipoma in Health, Safety and Environment from
Annamalai University in 2009.
B.sc from Sri Venkateswra University in 2008.
Intermediate from Board of Intermediate Education in 2005.
S.S.C from Board of Secondary Education in 2003.
WORKING EXPERIENCE:
Two years six months As a Safety Assistant in Aurobindo Pharma Pvt
Ltd. from 14th Aug 2008 to till date.
SKILLED AREAS:
Industrial Safety.
Staff Training & Mentoring.
Employee Safety Measures.
Documentation / Recordkeeping.
General Safety as required situational.
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JOB PROFILE:
Implementing safety systems.
Conducts or provides for employee safety training, including classroom
lectures, demonstrations or hands-on instruction.
Successfully handle the entire safety operation and played a key role in
implementing safety measures as well as developing Emergency plan.
Conducting internal safety audit on safety management system.
Inspection and Maintenance of portable fire extinguishers.
Operation and checking of fire hydrant system.
Procurement and maintaining of (PPEs) Personnel protective equipment.
Conduct Safety Induction for newly joined employees.
Issued all kind of Work Permit.
Identification of Unsafe acts and unsafe conditions.
Investigation of accidents and makes recommendation for prevention of similar future incidents.
Ensure the consistent reporting of all accidents, incidents or near misses to
the Manager
Ensure safety of personnel, equipment and environment by making
corrective action through conducting safety inspection at site.
Observes work in progress, ensures that proper safety equipment is worn
and procedures are followed.
Emergency planning and Fire prevention measures.
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PERSONAL PROFILE:
Name : D.srinivasulu Date of Birth : 23-05-1987
Age : 23
Father’s Name : D.Venkateswarlu
Marital Status : Unmarried
Hobbies : Reading Books, Watching TV.Languages Known : English, Hindi, and Telugu.Permanent Address : Narasingupalli (village),
Porumamilla (mandal), Y.S.R (District),
Andhra Pradesh.
Pin: 516193
India.
I HAVE POSSPORT
DECLARATION
I hereby declare that the information given above is true and correct to thebest of my knowledge.
DATE: 22/03/11
PLACE: Hyderabad (D.Srenivasulu)
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FACTBOX-The 20 largestpharmaceutical companies
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Related Topics
• Stocks » • Mergers & Acquisitions » • Global Markets » • Healthcare »
Stocks
Pfizer IncPFE.N$19.88-0.10-0.50%8:21pm GMT+0530 Merck and Co IncMRK.N$32.66+0.27+0.83%8:21pm GMT+0530
Fri Mar 26, 2010 1:00pm EDT
March 26 (Reuters) - The following is a list of the top 20
pharmaceutical companies, ranked by global prescription drug
sales for the 12 months through September 2009, according to
pharmaceutical market research company IMS Health Inc.
The chart shows sales -- in billions of U.S. dollars -- and
percent change over the period. The data does not include the
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results from mega acquisitions by Pfizer (PFE.N) and Merck
(MRK.N), as their deals for Wyeth and Schering-Plough,
respectively, were completed in the fourth quarter.
A year after a wave of mega-mergers shook up the
pharmaceutical industry, the remaining big drugmakers most
often mentioned as takeout or merger candidates appear set to
go it alone as they edge toward their patent cliffs.
[ID:nN26144801]
Company Sales pct change
1) Pfizer $41.7 (0.8)
2) Novartis $36.7 7.0
3) Sanofi-Aventis $35.1 3.3
4) GlaxoSmithKline $34.3 (3.4)
5) AstraZeneca $33.2 7.8
6) Roche $31.3 8.6
7) Johnson & Johnson $26.9 (6.6)
8) Merck & Co $25.0 (4.1)
9) Eli Lilly $19.6 8.3
10) Abbott $19.4 5.5
11) Teva $15.7 12.3
12) Bayer $15.4 3.913) Wyeth $14.8 (2.3)
14) Amgen $14.8 (3.1)
15) Boehringer $14.6 10.4
16) Takeda $14.4 2.1
17) Bristol-Myers $14.2 5.8
18) Schering-Plough $13.1 4.3
19) Daiichi Sankyo $8.5 3.1
20) Novo Nordisk $8.2 11.6
(Source: IMS Health)
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After reading this article, people also read:
• FACTBOX-World's top-selling drugs in 2014 vs 2010 Apr 13, 2010• Top 6 drugs tipped to be biotech products by 2014 Jun 17, 2009• Data shows declining productivity in drug R&D Jun 28, 2010• Special Report: Lilly's survival plan is far from generic Nov 10, 2010• Drugmakers face $140 bln patent loss: report May 2, 2007
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2010 Top 20 Pharmaceutical Companies
Report
Slowing sales, mega-mergers, generic implosions and whipsawing exchange rates havecaused some shakeups within the Top 20 Pharma ranks. The loss of Wyeth and Schering-Plough, coupled with Roche’s defection to the Biopharma list, led us to find several newplayers: Otsuka, Gilead and Mylan.
Photo courtesy of Boehringer-Ingelheim GmbH •
Validation of filtration unit in Biberach,Germany
I’m not sure how significant it is that half of “the second tier” (companies 11-20) arebased in Japan, but I find it interesting that Gilead (#19) is the only non-generic U.S.pharma company in that tier. (Just below the cutoff line, companies #21 and #22 areDutch and Japanese, respectively.) I also find it interesting that Teva has revenue goalsthat could propel it into the top 7 ranks in the next few years. Aim high, pharma!
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— Gil Y. Roth, Editor
Top 20 Pharmaceutical Companies
01 Pfizer $45,448
02 Sanofi-Aventis $40,871
03 Novartis $38,45504 GlaxoSmithKline $36,746
05 AstraZeneca $31,905
06 Merck & Co. $26,929
07 Johnson & Johnson $22,520
08 Eli Lilly & Co. $20,629
09 Bristol-Myers Squibb $18,808
10 Abbott Laboratories $16,486
11 Takeda Chem. Ind. $14,204
12 Boehringer-Ingelheim $14,027
13 Teva Pharma $13,81414 Bayer Schering $13,344
15 Astellas $10,509
16 Daiichi-Sankyo $9,757
17 Eisai $8,441
18 Otsuka $7,717
19 Gilead Sciences $6,469
20 Mylan $5,015
Based on 2009 pharma revenues.
Note: In all Top Company profiles, dollar amounts are in millions.
Contributors
Editor: Gil Y. RothAssociate Editor: Kristin BrooksContributing Editor: Derek B. Lowe
All profiles written by Gil Roth, except Astellas and Daiichi-Sankyo, by Kristin Brooks.
The Lowe Down capsules written by Derek Lowe
All pipeline information compiled by Kristin Brooks
Sales information compiled by Gil Roth
Visit our Top 10 Biopharma companies report!
Back to the July/August 2010 issue
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Home » Articles » List of Top 10 Pharmaceutical Companies in
India
List of Top 10 Pharmaceutical
Companies
in India
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In the list of top pharmaceutical companies in India it is not the Indian companies butalso the MNCs that are becoming the part of the race. Indian pharmaceutical market in
2008 was $7,743m and if compared to year 2007 it was 4% more than that. It is expectedthat Indian pharmaceutical market will grow more than the global pharmaceutical marketand will become $15,490 million in 2014. Today Indian pharmaceutical industry is thesecond most fastest growing industry displaying the revenue of Rs 25,196.48 crore andgrowth of 27.32 percent. Top pharmaceutical companies in India are also acquiring thesmall companies worldwide to further expand the market. Pharmaceutical drugs injections, tablets, capsules, syrups are the products of pharma companies in India alongwith many more.
Looking back into history reveals that it was in 1930 when the first pharmaceuticalcompany in India came into existence in Kolkatta. It is called the "Bengal Chemicals and
Pharmaceutical Works". This Indian company is still there and today it is the part of fivedrug manufacturing companies that are owned by the government. Till the period of 60years the pharmaceutical industry in India was overshadowed by the foreign drugmanufacturing companies but with the Patent Act in 1970, the whole scenario of pharmaceutical companies in India had changed since then. With this the Indian marketwas more open to Indian pharmaceutical companies than the MNCs. So with thispharmaceutical companies in India started to grow in number
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At present there is a cut throat competition among top pharmaceutical companies inIndia with the native as well as MNCs. But there are certain issues that are concerning thegrowth of pharma companies in India. These are:
• Mandatory licensing and failure of new paten system.•
Regular power cuts and inadequate infrastructure.• Restricted funding.• Regulatory hindrances that lead to the delays in the launch of new drug or pharma
product.• Too many small as well as big pharmaceutical companies and excessive
competition.
Top 10 Pharmaceutical Companies in India
1. Ranbaxy
With a 2007 turnover of Rs 4,198.96 crore (Rs 41.989 billion) by sales, Ranbaxyis the largest pharmaceutical company in India.
2. Dr Reddy's Laboratories
With the turnover of Rs 4,162.25 crore (Rs 41.622 billion), Dr Reddy'sLaboratories is the second largest pharmaceutical company in India.
3. Cipla
With the revenue of Rs 3,763.72 crore (Rs 37.637 billion) Cipla is the thirdlargest pharmaceutical company in India.
4. Sun Pharma Industries
Sun Pharma Industries is the fourth largest pharma company in India with thetotal revenue of Rs 2,463.59 crore (Rs 24.635 billion) and led by Dilip Sanghvi.
5. Lupin Labs
Lupin Labs has the total revenue of Rs 2,215.52 crore (Rs 22.155 billion
6. Aurobindo Pharma
Sales revenues stood at Rs 2,080.19 crore (Rs 20.801 billion) makes it the sixthlargest pharmaceutical company in India.
7. GlaxoSmithKline Pharma (GSK)
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GSK is the seventh largest pharma company with the total sales revenue of Rs1,773.41 crore (Rs 17.734 billion)
8. Cadila Healthcare
Eight largest company has the total sale revenue at Rs 1,613.00 crore (Rs 16.13billion)
9. Aventis Pharma
Aventis Pharma has the revenue of Rs 983.80 crore (Rs 9.838 billion) and theninth largest pharmaceutical company in India.
10. Ipca Laboratories
Revenue of Rs 980.44 crore (Rs 9.804 billion) makes Ipca India's 10th largest
pharma firm by sales.Ads by Google
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Learn about commonly misunderstood food-drug interactions. : www.druginteractioncenter.org
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Copyright © Pharmaceutical &
EHSTodayOSHA attorney ArtSapper revealsrecordkeepingmistakes p. 36
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Sustainability and ROI...........49Hand Protection................... 53Industrial Manslaughter........59
Plus36 www.EHStoday.com I SEPTEMBER 2010 I EHSToday
OSHARecordkeeping
QuestionsOne of the nation’stop OSHA lawattorneys sharesthe list of commonrecordkeepingmistakes he sees
employers making.
Now that OSHA under President
Obama has warnedemployers that “there is anew sheriff in town” and is movingtoward electronic reportingof injuries and illnesses, employersshould be on the lookout forthese common errors on theirOSHA 300 logs.During my years of advising employerson OSHA recordkeeping,auditing their records, and defendingthem against OSHA recordkeepingcitations, my colleaguesand I have been struck by how
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often we find employers makingthe same mistakes on their OSHA300 logs. Here is my top 10 list of mistakes employers make on theirOSHA 300 logs.
B y Arthu r G . Sapper10 (Employers Get Wrong)38 www.EHStoday.com I SEPTEMBER 2010 I EHSToday>>10 OSHA Recordkeeping Questions (Employers Get Wrong)1.) Misundersta ndingWork RestrictionsThe single most common error I havefound employers making is misunderstandingwhat an OSHA-recordablework restriction is. Employers commonly– but honestly – believe that
an injury is not recordable as a workrestriction if the injured employee stillcan perform useful work. Thus, I haveseen employers try to avoid an OSHArecordable by assigning office work toinjured carpenters. Other employersbelieve that the case is not recordableif the employee still can perform workwithin his or her job description. Forexample, they give purely sedentarywelding work to ironworkers who otherwise
would daily climb ladders toperform welding.Both ideas are wrong. OSHA’s regulations(29 C.F.R. § 1904.7(b)(4)(i)-(ii))state that a restriction occurs when eitherone of two circumstances occur:the employer keeps an occupationallyinjured employee from performingone or more “routine functions” of hisjob; or a licensed health care professionalrecommends that the employee
not perform one or more “routine functions”of his job. The term “routine function”is defined as a work activity regularlyperformed at least once per week.In the case of the injured welder whonow is unable to climb a ladder, thecase is recordable because he climbsladders every day.
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These misconceptions neverthelesshave all the tenacity of original sin. Theywere common even before the 2001overhaul of the recordkeeping regulations.The 1989 OSHA-commissioned
Keystone Report stated the consensusof knowledgeable persons from OSHA,industry and unions that “the recordingof restricted work is perhaps theleast understood and least acceptedconcept in the recordkeeping system.”(Keystone Center, “Keystone NationalPolicy Dialogue on Work-Related Illnessand Injury Recording,” 1989). Thatstill is the case.2.) “Light Duty” Can Be A
Recordable RestrictionAnother common misconception isthat light duty is not a work restriction. Arecordkeeping regulation (§ 1904.7(b)(4)(vii)) indicates that light duty canindeed amount to a work restriction.The regulation indicates – albeit indirectly– that light duty is presumptivelya restriction.The regulation starts with the question,“How do I handle vague restrictions
from a physician or other licensedhealth care professional, suchas that the employee engage only in‘light duty’ or ‘take it easy for a week’?”After stating that the employer “may”ask the physician whether this meansthat the employee may not perform allof his routine job functions or work hisentire normally assigned work shift, thelengthy provision ends with this: “If youare unable to obtain this additional
information from the physician … whorecommended the restriction, recordthe injury or illness as a case involvingrestricted work.”OSHA officials take this last sentenceto mean that “light duty” is a recordablework restriction unless the physicianaffirmatively states that the employee
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may perform all of his routine job functionsand may work a full shift. Therefore,I advise employers that, whenfaced with a vague restriction such as“light duty,” they should contact the
physician and get clarification on whattasks the employee may not perform. If one of these tasks is one that the employeeregularly performs at least oncea week, an OSHA recordable case mustbe entered on the log.Another aspect of work restrictionsthat employers overlook is that therecordability of a restriction dependson that particular employee’s routinefunctions. Hence, two employees can
be identically injured, treated and restricted,but the restriction might berecordable for only one of them. A restrictionfor an ironworker might notbe a restriction for a receptionist. Anemployer needs to review with theemployee or his immediate supervisorwhat tasks the employee regularly performsat least once per week and askwhether the restriction prevents anyfrom being performed.
3.) Missing An Importa ntWitness – The InjuredEmployeeAnother common error is to fail to giveproper weight to the account of theinjury offered by the injured employee.I have seen employers discount anemployee’s version of events becausethere were “no witnesses.”Employers often forget that the injuredemployee is a witness. If the employee
says that he twisted his anklewhen he stepped on a rock, the employee’saccount must be given asmuch weight as the circumstanceswarrant. It cannot be ignored becausethe employee cannot corroborate it;sometimes the employee’s statement isenough. And if it is not enough, the prudent
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employer will document the factsand reasons indicating why it is not.40 www.EHStoday.com I SEPTEMBER 2010 I EHSToday>>10 OSHA Recordkeeping Questions (Employers Get Wrong)4.) Excessive Reliance on
the Employee’s Failureto Immediate ly ReportEmployers sometimes fail to recordan injury because the employee didnot report it immediately or on thesame day it allegedly happened. Theythought that the employee’s failure toimmediately report is fatal to his credibility,especially if the failure violatedthe company’s immediate-reportingrule. Employers also fear that recording
the injury would undermine their rule.Such reasoning is understandablebut incorrect. Although the employee’sfailure to immediately report may underminehis credibility and may violatethe employer’s reporting rule, it doesnot necessarily mean that a work-relatedinjury did not occur. It may wellbe that the employee initially thoughtthat the injury was too minor to reportbut found that, upon awakening the
next morning, the injury feels worse.Even though the injury was reportedlate, in violation of the employer’srule, the employer still must ask himself whether the employee’s accountis credible, including whether there isother convincing countervailing evidenceto dispute his account.5.) Misundersta ndingAggravat ion –Understa ndably
One of the most common errors thatemployers make is misunderstandingOSHA’s test for recordability of a workplaceaggravation of a non-occupationalinjury. Employers often think that if anon-the-job incident caused a flare-up of an injury that originally occurred off thejob or with a previous employer, the aggravation
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is not recordable. This often isincorrect. But what makes the situationworse is that OSHA’s regulations on thispoint are misleading.Consider an employee who gets a bad
case of tennis elbow on vacation, returnsto work and picks up a small box of pencils.Suppose the lifting of the pencil boxtips her already-precarious elbow overthe edge and causes her to either requiremedical treatment or makes her unableto perform her normal weekly typing. Isthe case recordable?It would be understandable for anemployer to think that the pencil boxincident may be ignored as an insignificant
aggravation. First, the principalprovision on aggravation in theregulations (§ 1904.5(b)(3) says thatan aggravation is not recordable unlessthe current workplace “significantly”aggravated the previous nonoccupationalcondition. Second, thepreamble to the regulations describesthe provision as not “requir[ing] therecording of cases involving only minoraggravation of preexisting conditions.”
So a reasonable employer mightthink that the regulations permit himto distinguish between significant andinsignificant aggravations.That employer would be wrong;another provision in the regulations(§ 1904.5(b)(4)) takes away what theword “significantly” and the preambleappear to promise. That provision defines“significantly” aggravated as beingsevere enough to tip a non-occupational
injury into the usual recordabilitycriteria. It states that if a restrictionis imposed or medical treatment isrequired because a discernable workplaceevent or exposure has aggravateda non-occupational condition,the case is recordable.This special definition not only is
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out of character with the wording andpreamble of the regulation, but meansthat what normal people would consideran insignificant aggravation is“significant” and thus recordable. Employers
can and should be forgivenfor being mystified by a regulationthat speaks of “significant” aggravationbut requires them to record a case thecause of which is 99.99 percent nonoccupational.6.) Applying or BeingInfluenced by Non-OSHA RecordkeepingCriteriaAnother phenomenon I have seen isphysicians and employers applying or
being influenced by non-OSHA criteriafor work-relatedness, aggravationsand restrictions.For example, employers commonlyask a doctor whether an aggravation iswork-related. This is fine if the employermeans to ask whether something onthe current job played any role in theemployee’s condition. But often a physicianresponds that the “preponderant”or “major” cause was something
non-occupational. This response oftenreflects the physician’s own commonsensetest for work-relatedness or aggravation,or that state’s workers’ compensationcriteria, which the physicianmay be more accustomed to applying.What this response does not reflect,however, is OSHA’s own special defini42www.EHStoday.com I SEPTEMBER 2010 I EHSToday>>10 OSHA Recordkeeping Questions (Employers Get Wrong)tion of aggravation, which does not ask
about “preponderant” or “major” causes.Employers therefore should be alertfor signs their physicians are failing toapply OSHA’s definition or approachesto recordkeeping.This problem affects more thanphysicians. It often affects employers’recordkeepers, because they nearly
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always are the same people whom employersentrust with the responsibilityto determine compensability underworkers’ compensation law. Criteria forrecordability and compensability are
similar enough to be confused, andfor the application of one to influencethe other. This is understandable, for itis difficult and counter-intuitive to saythat a case is not work-related or aggravatedfor compensability purposes butis recordable for OSHA purposes.This conceptual spillover also affectswork restrictions. Workers’ compensationinsurers lately have urged employersthat to promote healing, maintain
employee morale and lower compensationcosts, employees be kept workingas much as possible. Safety andhealth managers who have succeededin keeping injured employees fromlanguishing at home often find it psychologicallyhard, when reviewing thecase for OSHA recordability, to placethe case on the 300 log as an OSHArecordable restriction.7.) Some Common-Sense
First Aid Is RecordableMedical Treat mentUnder the recordkeeping regulations,medical treatment is recordable unlessit falls within an exception in the regulations,one of which is “first aid.” (See§ 1904.5(b)(5)(i)(C)). The regulationslist all treatments that are “first aid,” andthen state in paragraph (b)(5)(iii): “Areany other procedures included in firstaid? No, this is a complete list of all
treatments considered first aid for Part1904 purposes.”Despite this, I many times have encountered(even conscientious) employerswho think that if a treatment isfirst aid in common parlance, it is notrecordable. It does not occur to themthat because OSHA has created its own
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special and highly restricted definitionof “first aid,” there is a difference betweenfirst aid in common parlanceand “first aid” within the meaning of the OSHA regulations.
One example is the removal of foreignobjects from eyes with combinationinstruments called eye loops andmagnets. The use of these instrumentsis not “first aid” within the meaning of OSHA’s regulations because it is not onthe exclusive “first aid” list. That list saysthat “[r]emoving foreign bodies fromthe eye” is first aid “using only irrigationor a cotton swab[.]”Yet, combination eye loops and magnets
commonly are sold to employersas first aid devices that can removeobjects from the eye “with minimal intrusion.”One physician-written “Guidelinesfor Foreign Body Removal” in aWeb catalog states that “the magnetand the nylon loop” are “in the realmof first aid.” So while the regulationsmake clear that their use is not “firstaid,” it is understandable for employersto think otherwise.
8.) What Is APrescription Medicine?OSHA’s recordkeeping CIRCLE 147 ON READER CARD OR LINK TO THEVENDOR ONLINE AT www.ehsrs.biz/28696-147 rules state that44 www.EHStoday.com I SEPTEMBER 2010 I EHSToday>>10 OSHA Recordkeeping Questions (Employers Get Wrong)the use of a prescription drug is recordableas medical treatment. Employers oftenoverlook, however, that a physician’srecommendation for an employee touse even a non-prescription drug at
“prescription strength” is recordable.What is frustrating is that OSHA’sregulations state no way in which anemployer can determine what is a presc r i p t i o ndrug or a prescriptionstrength. Even OSHA’s online RecordkeepingHandbook (of which few
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employers are aware) inadequatelyaddresses the point; it states the prescriptionstrengths of only four overthe-counter drugs.The handbook does state that, to determine
the prescription-strength dosagesfor other non-prescription drugs,the employer “should contact OSHA,the United States Food and Drug Administration,their local pharmacist ortheir physician.” This is of little help.Not only are employers understandablyreluctant to call OSHA but areaoffices are busy enough that it can bedifficult to get a knowledgeable personon the phone. Moreover, different
OSHA offices have been known to offerdifferent advice.OSHA’s advice to call the FDA isunhelpful, as the handbook does notprovide a phone number and and theFDA is a huge organization. Althoughonline FDA databases have this information,they are very difficult to useand provide unclear results. Calling localpharmacists and physicians oftenis unsatisfactory as they are busy and,
in my experience, have been unsureand even wrong when asked for theprescription dose of a drug.OSHA should state (or arrange withthe FDA to make clear on its Web site)what dose of each FDA-approved drugrequires a prescription.9.) Unringing the BellEmployers sometimes try to avoid arecordable case by asking a secondphysician for his opinion on whether
a certain medical treatment given by,or a certain restriction recommendedby, a previous physician was needed,or whether an injury or aggravationis occupational. This seems to be permittedby OSHA’s regulations, whichtwice state that, “If you receive recommendationsfrom two or more
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physicians or other licensedhealth care professionals,you may make a decisionas to which recommendationis the most authoritative,
and record the casebased upon that recommendation.”§§ 1904.7(b)(3)(ii) and (b)(4)(viii).The trouble is that OSHA’s regulationsfail to make clear some finedistinctions that OSHA enforcementofficials draw. Under these distinctions,sometimes the second physician mayunring a bell rung by the first physician,and sometimes he may not.
OSHA has issued interpretationletters indicating that, once the firstphysician has actually treated the employeemedically, or the employee hasactually worked under a restrictionor missed part a day of work, the bellcannot be unrung. “The employer maynot consider a conflicting recommendationonce medical treatment, daysaway from work or restricted workactivity have taken place, even if the
subsequent recommendation is moreauthoritative” (Letter to D.F. Coble; May15, 2007; http://www.osha.gov/pls/ osha web/owadisp.show_document?p_table=INTERPRETATIONS&p_i d =25696).According to OSHA interpretations,the employer may follow the secondphysician’s opinion as to restrictions,lost work time or medical treatmentonly if (a) he finds it more authoritative;
(b) the opinion is “contemporaneous”with the injury; and (c) if theemployee has not yet worked underthe first physician’s recommendationfor restriction or time away from work,and has not yet received medicaltreatment from the first physician. SeeQuestion 7-10a in OSHA’s Detailed Frequently
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Asked Questions for OSHA’sInjury and Illness Recordkeeping Rule.Elements (b) and (c) are not in thetext of the regulations but OSHA followsthem anyway.
Another circumstance in which thebell may be unrung pertains to workrelatednessand aggravation. Initialconclusions on these points can berebutted later by a second physician’sopinion and by other evidence too.This distinction is implicit in the regulationsand followed by OSHA, thoughit does not appear in any interpretationletter or guidance document of which I am aware.
10.) Not TrackingLate r EventsIt is common for employers to fall preyto the old adage, “out of sight, out of mind.” Once an injured employee hasstopped reporting for work becausehe is on long-term injury leave, recordkeepersforget to keep track of his daysaway from work and put them on thelog. The same thing frequently occurswhen injured employees make subsequent
physician visits remote in timefrom the injury; on these occasions,restrictions may be imposed, medicaltreatments given or drugs prescribedof which the employer is unaware.Employers need to establish a systemfor keeping tabs on these subsequentevents and for making sure that their recordkeepersconsistently track them. If not, recordable cases or data might slipthrough the cracks and not be reflected
on the employer’s OSHA 300 log.OSHA is laying the groundwork fora requirement that employers electronicallyfile their OSHA 300 and300A forms; this will help OSHA findpatterns of under-recording and targetemployers for recordkeeping inspections.Employers therefore should review
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their logs and interview their recordkeepersto determine if the aboveerrors have been made. Employersshould do this now, before OSHA doesit for them.
Arthur G. Sapper is a partner in theOSHA Practice Group of McDermott Will & Emery, a former deputy general counsel of the Occupational Safety and Health Review Commission and aformer professor of OSHA law. He hasparticipated in numerous audits and cases involving OSHA injury recordkeeping,and can be reached at 202-
756-8246 or [email protected].
Hazardous Energy Control
Sample Written Program
This sample program has been prepared to provide assistance in compliance with USAOSHA standards and/or Best Management Practices. It should not be used withoutconsideration of the unique conditions and requirements at each site. It may be necessaryto modify the program for your specific needs. You remain under obligation to complywith all applicable standards, and use of this program should not be considered to be aguarantee that compliance with applicable requirements will be achieved. It is stronglysuggested that your final program be reviewed by a qualified person. The best writtenprogram without implementation is inadequate.
HAZARDOUS ENERGY CONTROL
This sample hazardous energy control program has been prepared to provide assistance incompliance with OSHA standard 1910.147. It should not be used without considerationof the unique conditions and requirements at each site. It may be necessary to modify thesample program for your specific needs. You remain under the obligation to comply withall applicable standards, and use of this program should not be considered to be a
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guarantee that this compliance will be achieved. It is suggested that your final program bereviewed by a qualified person.
The referenced standard is entitled, "The Control of Hazardous Energy (lockout/tagout)",but tagout has deliberately not been included in the sample program. This standard
requires lockout unless "the employer can demonstrate that the utilization of a tagoutsystem will provide full employee protection as set forth in paragraph (c)(3) of thissection" [see 1910.147 (c)(2)(ii)].
Since there is a much greater risk of employee injury when tagout is used and with theavailability of a variety of heavy-duty rigid plastic lockout adapter devices available onthe market, tagout is not recommended.
I. PURPOSE
The purpose of this program is to protect employees from injuries while servicing andmaintaining equipment.
II. SCOPE
The program establishes requirements for hazardous energy control. It is to be used toensure that machines and equipment are isolated from all potentially hazardous energysources whenever servicing or maintenance activities are in progress.
III. RESPONSIBILITY
1. The _____________________________ is designated as the Program Coordinator for this company. Specific responsibilities include:
a. Provide Hazardous Energy Control training to employees.
b. Maintain a current listing of employees who have completed lockout training(Attachment 1).
c. Maintain a current listing of all equipment/machines which fall under the HazardousEnergy Control program (Attachment 2). Listing is to be updated each time a changeoccurs.
d. Implementation and enforcement of this program.
e. Maintain an adequate supply of padlocks and DANGER tags for use each time alockout process is performed. Padlocks and tags are located_________________________________.
f. Conduct the annual inspection & review as required by section VII of this program.
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1. Notify the Program Coordinator.
2. Notify all affected employees that lockout is going to be utilized, and the reason why.
3. If the machine/equipment is in operation, shut it down by the normal shutdown
procedure.
4. Operate the appropriate switch, valve, etc., so that the machine/equipment is isolatedfrom the energy source.
5. Lock the energy isolating devices, using assigned locks and danger tags.
6. Release, restrain, or dissipate any stored energy.
7. Verify that energy isolation is complete, by attempting to start the affected machineryor equipment in the normal manner.
8. After testing, return all operation controls to the "neutral" or "off" positions.
B. RESTORATION TO NORMAL:
1. After service or maintenance is complete, check the area to ensure that no employeesare exposed.
2. Remove all tools and repair equipment.
3. Ensure that all guards have been replaced and all safety interlocks reactivated (if so
equipped).
4. Verify that the operating controls are in the "off" or neutral position.
5. Remove all lockout and tag devices and activate the energy isolation devices to restoreenergy.
VII. PROGRAM INSPECTION AND REVIEW
At least annually, a designated representative will verify the effectiveness of the energycontrol procedures. These inspections shall provide for a demonstration of the procedures
and may be carried out through random audits and observations.
The inspector must review the Hazardous Energy Control Procedure with all authorizedemployees, and actually observe the use of the Hazardous Energy Control Procedure.This inspection must be certified and documented by the inspector using a HazardousEnergy Control Lockout Program Inspection form. (Attachment 3).
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These inspections are to ensure that the energy control procedures are being properlyused, and to provide a check on the continued adherence to the procedures. Managementmust certify that the prescribed inspections have been performed. Any deficiencies mustbe corrected immediately, either by modification of the procedure, retraining of employees, or a combination of both.
VIII. OUTSIDE CONTRACTORS
Outside personnel or contractors involved in lockout of equipment or machinery thataffects our employees must submit their energy control procedures, in writing, to theProgram Coordinator. All affected employees must be trained in and familiar with thecontractor's submitted procedure.
In order to protect our employees, the contractor's work area will be isolated, and accessby our employees will be restricted. If this is impractical or cannot be accomplished, theProgram Coordinator must assure the contractor's compliance with proper work
procedures, energy isolation procedures and contractor employee compliance.
Contractors failing to adhere to the provisions of the OSHA Hazardous Energy Controlstandard will be asked to terminate their work until their program is brought intocompliance.
Attachment 1
HAZARDOUS ENERGY CONTROL
PROGRAM TRAINING RECORD
The following company employees have received Hazardous Energy Control (Lockout)training.
NAME DEPT TYPE OF TRAINING DATE
-----------------------------------------------------------
Attachment 2
HAZARDOUS ENERGY CONTROL
LOCKOUT EQUIPMENT LISTING
The following machines and equipment fall under the requirements of 29 CFR 1910.147,the Control of Hazardous Energy (Lockout/Tagout). For this reason appropriate lockoutprocedures must be performed each time servicing or maintenance is performed.
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EQUIPMENT/MACHINE IDENTIFICATION LOCATION DATE LISTED
-----------------------------------------------------------
Attachment 3
HAZARDOUS ENERGY CONTROL
LOCKOUT PROGRAM INSPECTION
DATE: _______________
EQUIPMENT IDENTIFICATION:
INSPECTION:
AUTHORIZED EMPLOYEES (JOB TITLES)
1. ___________________________________________ 4.__________________________________________
2. ___________________________________________ 5.__________________________________________
3. ___________________________________________ 6.__________________________________________
PROCEDURES BEING FOLLOWED: Y / N
COMMENTS/DEFICIENCIES
DEFICIENCY FOLLOW-UP: COMPLETED ________________________ N/A
DATE
COMMENTS
REVIEWED BY:_____________________________________________ DATE:__________________
_____________________________________________ DATE: __________________
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Control Of Hazardous Energy(Lockout/Tagout)
This informational article is intended to provide a generic, non-exhaustive overview of 29 CFR 1910.147, Control of Hazardous Energy (Lockout/Tagout). This information
does not itself alter or determine compliance responsibilities, which are set forth inOSHA standards themselves and the Occupational Safety and Health Act. Moreover,because interpretations and enforcement policy may change over time, for additionalguidance on OSHA compliance requirements, the reader should consult currentadministrative interpretations and decisions by the Occupational Safety and Health
Review Commission and the courts.
ContentsIntroduction
Scope and Application
Normal Production OperationsServicing and/or Maintenance OperationsMinor Servicing Tasks
Provisions of the Standard
Energy Control ProgramEnergy Control Procedure
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Energy-Isolating DevicesRequirements for Lockout/Tagout DevicesEmployee TrainingPeriodic InspectionsApplication of Controls and Lockout/Tagout Devices
Removal of Locks and TagsAdditional Safety Requirements
Glossary
IntroductionOn September 1, 1989, OSHA issued a final rule on the Control of Hazardous Energy
(Lockout/Tagout) of Title 29 of the Code of Federal Regulations (29 CFR) Part1910.147. This standard, which went into effect on January 2, 1990, helps safeguardemployees from the unexpected startup of machines or equipment or release of hazardousenergy while they are performing servicing or maintenance. The standard identifies the
practices and procedures necessary to shut down and lock out or tag out machines andequipment, requires that employees receive training in their role in the lockout/tagoutprogram, and mandates that periodic inspections be conducted to maintain or enhance theenergy control program.
In the early 1970's, OSHA adopted various lockout-related provisions of the then existingnational consensus standards and Federal standards that were developed for specific typesof equipment or industries. When the existing standards specify lockout, the new rulesupplements these existing standards(1) by requiring the development and utilization of written procedures, the training of employees, and periodic inspections of the use of theprocedures.
This rule requires that, in general, before service or maintenance is performed onmachines or equipment, the machines or equipment must be turned off and disconnectedfrom the energy source, and the energy-isolating device must be either locked or taggedout.
OSHA has determined that lockout is a more reliable means of deenergizing equipmentthan tagout and that it should always be the preferred method used by employees. TheAgency believes that, except for limited situations, the use of lockout devices willprovide a more secure and more effective means of protecting employees from theunexpected release of hazardous energy or startup of machines and equipment.
Approximately 39 million workers are protected by this rule. (The 3 million workers whoactually service equipment -- i.e., craft workers, machine operators, and laborers -- facethe greatest risk.) OSHA estimates that compliance with the standard prevents about 122fatalities, 28,400 lost workday injuries, and 31,900 non-lost workday injuries each year.
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OSHA estimates that adherence to the requirements of this standard can eliminate nearly2 percent of all workplace deaths in establishments affected by this rule and can have asignificant impact on worker safety and health in the U.S.
Employers and employees in the 25 states that operate OSHA-approved workplace safety
and health plans should check with their state agency. Their state may be enforcingstandards and other procedures that, while "at least as effective as" federal standards, arenot always identical to the federal requirements.
Scope and ApplicationThe lockout/tagout standard applies to general industry employment and covers theservicing and maintenance of machines and equipment in which the unexpected startup or the release of stored energy could cause injury to employees. The standard applies to anysource of mechanical, hydraulic, pneumatic, chemical, thermal, or other energy, but doesnot cover electrical hazards. Subpart S of 29 CFR Part 1910 covers electrical hazards, and29 CFR Part 1910.333 contains specific lockout/tagout provisions for electrical hazards.
(If employees are performing service or maintenance tasks that do not expose them to theunexpected startup of machines or equipment, energization, or release of hazardousenergy, the standard does not apply.)
The standard establishes minimum performance requirements for the control of hazardous energy.
The standard does not apply in the following situations:
• While servicing or maintaining cord and plug connected electrical equipment,provided that the equipment is unplugged from the energy source; and the plug
remains under the exclusive control of the employee performing the servicingand/or maintenance; and
• During hot tap operations that involve transmission and distribution systems for gas, steam, water, or petroleum products when they are performed on pressurizedpipelines provided that continuity of service is essential, shutdown of the systemis impractical, and employees are provided with alternative protection that isequally effective.
Normal Production OperationsOSHA recognizes that machines and equipment present many hazardous situations
during normal production operations -- i.e., whenever machines and equipment are usedto perform their usual production function. These production hazards are covered by rulesin other General Industry Standards, such as the requirements in Subpart O of Part 1910for general machine guarding and guarding power transmission apparatus (29 CFR Part1910.212 and 1910.219). In certain circumstances, however, some servicing or maintenance hazards encountered during normal production operations may be coveredby the lockout/tagout rule. The following paragraphs illustrate some of these instances.
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Servicing and/or Maintenance Operations
If a servicing activity -- such as lubricating, cleaning, or unjamming the productionequipment -- takes place during production, the employee performing the servicing may
be subjected to hazards that are not encountered as part of the production operation itself.Workers engaged in these operations are covered by lockout/tagout when any of thefollowing conditions occur:
• The employee must either remove or bypass machine guards or other safetydevices, resulting in exposure to hazards at the point of operation;
• The employee is required to place any part of his or her body in contact with thepoint of operation of the operational machine or piece of equipment; or
• The employee is required to place any part of his or her body into a danger zoneassociated with a machine operating cycle.
In the above situations, the equipment must be deenergized and locks or tags must beapplied to the energy-isolation devices.
In addition, when other servicing tasks occur -- such as setting up equipment, and/or making significant adjustments to machines -- employees performing such tasks arerequired to lock out or tag out if they can be injured by unexpected energization or startupof the equipment.
OSHA also recognizes that some servicing operations must be performed with the power on. Making many types of fine adjustments, such as centering the belt on conveyors, is
one example. Certain aspects of troubleshooting, such as identifying the source of theproblem as well as checking to ensure that it has been corrected, is another. OSHArequires the employer to provide effective protection when employees perform suchoperations. Although, in these cases, a power-on condition is essential either toaccomplish the particular type of servicing or to verify that it was performed properly,lockout or tagout procedures are required when other service or maintenance occurs andpower is not required.
Minor Servicing Tasks
Employees performing minor tool changes and adjustments and/or other minor servicingactivities that are routine, repetitive, and integral to the use of the productionequipment and that occur during normal production operations are not covered by thelockout/tagout standard, provided the work is performed using alternative measures thatprovide effective protection.
Provision of the Standard
The standard requires employers to establish procedures for isolating machines or
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equipment from their source of energy and affixing appropriate locks or tags to energy-isolating devices to prevent any unexpected energization, startup, or release of storedenergy that could injure workers. When tags are used on energy-isolating devices capableof being locked out, the employer must provide additional means to assure a level of protection equivalent to that of locks. The standard also requires the training of
employees, and periodic inspections of the procedures to maintain or improve their effectiveness.
Energy Control Program
The lockout/tagout rule requires that the employer establish an energy control programthat includes (1) documented energy control procedures, (2) an employee trainingprogram, and (3) periodic inspections of the use of the procedures. The standard requiresemployers to establish a program to ensure that machines and equipment are isolated andinoperative before any employee performs servicing or maintenance when the unexpectedenergization, start up, or release of stored energy could occur and cause injury.
The purpose of the energy control program is to ensure that, whenever the possibility of unexpected machine or equipment startup or energization exists or when the unexpectedrelease of stored energy could occur and cause injury during servicing and maintenance,the equipment is isolated from its energy source(s) and rendered inoperative prior toservicing or maintenance.
Employers have the flexibility to develop programs and procedures that meet the needs of their particular workplace and the particular types of machines and equipment beingmaintained or serviced.
Energy Control Procedure
This standard requires that energy control procedures be developed, documented, andused to control potentially hazardous energy whenever workers perform activitiescovered by the standard.
The written procedures must identify the information that the authorized(2) employeesmust know to control hazardous energy during servicing or maintenance. If thisinformation is the same for various machines or equipment or if other means of logicalgrouping exists, then a single energy control procedure may be sufficient. If there are
other conditions -- such as multiple energy sources, different connecting means, or aparticular sequence that must be followed to shut down the machine or equipment -- thenthe employer must develop separate energy control procedures to protect employees.
The energy control procedures must outline the scope, purpose, authorization, rules, andtechniques that will be used to control hazardous energy sources as well as the means thatwill be used to enforce compliance. At a minimum, they should include, but not belimited to, the following elements:
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• A statement on how the procedures will be used;
• The procedural steps needed to shut down, isolate, block, and secure machines or equipment;
• The steps designating the safe placement, removal, and transfer of lockout/tagout
devices and who has the responsibility for them;• The specific requirements for testing machines or equipment to determine and
verify the effectiveness of locks, tags, and other energy control measures; and• The employer or an authorized employee must notify affected employees before
lockout or tagout devices are applied and after they are removed from themachine or equipment.
The procedures must include the following steps: (1) preparing for shutdown, (2) shuttingdown the machine or equipment, (3) isolating the machine or equipment from the energysource(s), (4) applying the lockout or tagout device(s) to the energy-isolating device(s),(5) safely releasing all potentially hazardous stored or residual energy, and (6) verifying
the isolation of the machine or equipment prior to the start of servicing or maintenancework.
In addition, before lockout or tagout devices are removed and energy is restored to themachines or equipment, certain steps must be taken to reenergize equipment after servicing is completed, including: (1) ensuring that machines or equipment componentsare operationally intact; (2) ensuring that all employees are safely positioned or removedfrom equipment; (3) ensuring that lockout or tagout devices are removed from eachenergy-isolating device by the employee who applied the device. (See sections 6 (e) and6 (f) of 29 CFR Part 1910.147 for specific requirements of the standard.)
Energy-Isolating Devices
The employer's primary tool for providing protection under the standard is the energy-isolating device, which is the mechanism that prevents the transmission or release of energy and to which locks or tags are attached. (See Glossary for a more completedefinition.) This device guards against accidental startup or the unexpected reenergizationin machines or equipment during servicing or maintenance. There are two types of energy-isolating devices: those capable of being locked and those that are not. Thestandard differentiates between the existence of these two conditions and the use of tagout when either condition exists.
When the energy-isolating device cannot be locked out, the employer must use tagout. Of course, the employer may choose to modify or replace the device to make it capable of being locked-out. When using tagout, the employer must comply with all tagout-relatedprovisions of the standard and, in addition to the normal training required for allemployees, must train his or her employees in the following limitations of tags:
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• Tags are essentially warning devices affixed to energy-isolating devices and donot provide the physical restraint of a lock.
• When a tag is attached to an isolating means, it is not to be removed except by theperson who applied it, and it is never to be bypassed, ignored, or otherwise
defeated.• Tags must be legible and understandable by all employees.• Tags and their means of attachment must be made of materials that will withstand
the environmental conditions encountered in the workplace.• Tags may evoke a false sense of security. They are only one part of an overall
energy control program.• Tags must be securely attached to the energy-isolating devices so that they cannot
be detached accidentally during use.
If the energy-isolating device is lockable, the employer must use locks unless he or shecan demonstrate that the use of tags would provide protection at least as effective as
locks and would assure "full employee protection."
Full employee protection includes complying with all tagout-related provisions plusimplementing additional safety measures that can provide the level of safety equivalent tothat obtained by using lockout. This might include removing and isolating a circuitelement, blocking a controlling switch, opening an extra disconnecting device, or removing a valve handle to reduce the potential for any inadvertent energization whiletags are attached.
Although OSHA acknowledges the existence of energy-isolating devices that cannot belocked out, the standard clearly states that whenever major replacement, repair,
renovation or modification of machines or equipment is performed and whenever newmachines or equipment are installed, the employer must ensure that the energy-isolatingdevices for such machines or equipment are lockable. Such modifications and/or newpurchases are most effectively and efficiently made as part of the normal equipmentreplacement cycle. All newly purchased equipment must be lockable.
Requirements for Lockout/Tagout Devices
When attached to an energy-isolating device, both lockout and tagout devices used inaccordance with the requirements of the standard help protect employees from hazardous
energy. A lockout device provides protection by preventing the machine or equipmentfrom becoming energized. A tagout device does so by identifying the energy-isolatingdevice as a source of potential danger; it indicates that the energy-isolating device and theequipment being controlled may not be operated while the tagout device is in place.Whichever devices are used, they must be singularly identified, must be the only devicesused for controlling hazardous energy, and must meet the following requirements:
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• Durability - lockout and tagout devices must withstand the environment to whichthey are exposed for the maximum duration of the expected exposure. Tagoutdevices must be constructed and printed so that they do not deteriorate or becomeillegible, especially when used in corrosive (acid and alkali chemicals) or wetenvironments.
• Standardized - Both lockout and tagout devices must be standardized accordingto either color, shape, or size. Tagout devices must also be standardizedaccording to print and format.
• Substantial - Lockout and tagout devices must be substantial enough to minimizeearly or accidental removal. Locks must be substantial to prevent removal exceptby excessive force of special tools such as bolt cutters or other metal cutting tools.Tag means of attachment must be nonreusable, attachable by hand, self-locking,and nonreleasable, with a minimum unlocking strength of no less than 50 pounds.
The device for attaching the tag also must have the general design and basic
characteristics equivalent to a one-piece nylon cable tie that will withstand allenvironments and conditions.
• Identifiable - Locks and tags must clearly identify the employee who appliesthem. Tags also must warn against hazardous conditions if the machine or equipment is energized and must include a legend such as the following: DO
NOT START, DO NOT OPEN, DO NOT CLOSE, DO NOT ENERGIZE,
DO NOT OPERATE.
Employee Training
The employer must provide effective initial training and retraining as necessary and mustcertify that such training has been given to all employees covered by the standard. Thecertification must contain each employee's name and dates of training.
For the purposes of the standard, there are three types of employees -- authorized,
affected, and other. The amount and kind of training that each employee receives isbased upon (1) the relationship of that employee's job to the machine or equipment beinglocked or tagged out, and (2) the degree of knowledge relevant to hazardous energy thathe or she must possess. For example, the employer's training program for authorized
employees (those who are charged with the responsibility for implementing the energy
control procedures and performing the servicing or maintenance) must cover, at aminimum, the following areas:
• recognition of applicable hazardous energy sources,
•
• details about the type and magnitude of the hazardous energy sources present inthe workplace, and
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• the methods and means necessary to isolate and control those energy sources (i.e.,the elements of the energy control procedures).
By contrast, affected employees (usually the machine operators or users) and all other
employees need only be able to (1) recognize when the control procedure is being used,
and (2) understand the purpose of the procedure and the importance of not attempting tostart up or use the equipment that has been locked or tagged out.
Because an "affected" or "other" employee is not performing the servicing or maintenance, that employee's responsibilities under the energy control program aresimple: Whenever there is a lockout or tagout device in place on an energy-isolatingdevice, the affected or other employee must leave it alone and not attempt to energize or operate the equipment.
Every employee training program must ensure that all employees understand the purpose,function, and restrictions of the energy control program and that authorized employees
possess the knowledge and skills necessary for the safe application, use, and removal of energy controls.
Training programs for authorized employees to comply with this standard, which isperformance-oriented, should deal with the equipment, type(s) of energy, and hazard(s)specific to the workplace being covered.
Retraining must be provided, as required, whenever there is a change in job assignments,a change in machines, equipment or processes that present a new hazard, or a change inenergy control procedures. Additional retraining must be conducted whenever a periodicinspection reveals, or whenever the employer has reason to believe, that there are
deviations from or inadequacies in the employee's knowledge or use of the energy controlprocedure.
Periodic Inspections
A periodic inspection of each procedure, when usage is at least once a year, must beperformed at least annually to assure that the energy control procedures continue to beimplemented properly and that the employees are familiar with their responsibilitiesunder those procedures. The periodic inspections must be designed to correct anydeviations or inadequacies observed. An authorized employee other than the one(s) using
the energy control procedure must perform the periodic inspections. In addition, theemployer must certify that the periodic inspections have been performed. Thecertification must identify the machine or equipment on which the energy controlprocedure was used, the date of the inspection, the employees included in the inspection,and the name of the person performing the inspection. For a lockout procedure, theperiodic inspection must include a review, between the inspector and each authorizedemployee, of that employee's responsibilities under the energy control procedure beinginspected. When a tagout procedure is inspected, a review on the limitation of tags, in
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addition to the above requirements, must also be included with each affected andauthorized employee.
Application of Controls and Lockout/Tagout Devices
The established procedure of applying energy controls includes the specific elements andactions that must be implemented in sequence.(3) These are briefly identified as follows:
(1) Prepare for shut down,
(2) Shut down the machine or equipment,
(3) Disconnect the energy isolating device,
(4) Apply the lockout or tagout device,
(5) Render safe all stored or residual energy, and
(6) Verify the isolation and deenergization of the machine or equipment.
Removal of Locks and Tags
Before lockout or tagout devices are removed and energy is restored to the machine or equipment, the authorized employee(s) must take the following actions or observe thefollowing procedures:
(1) Inspect the work area to ensure that non-essential items have been removed and thatmachine or equipment components are intact and capable of operating properly;
(2) Check the area around the machine or equipment to ensure that all employees havebeen safely positioned or removed,
(3) Make sure that locks or tags are removed ONLY by those employees who attachedthem. (In the very few instances when this is not possible, the device may be removedunder the direction of the employer provided that he or she strictly adheres to the specificprocedures outlined in the standard); and
(4) Notify affected employees after removing locks or tags and before starting equipmentor machines.
Additional Safety Requirements
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Special circumstances exist when (1) machines need to be tested or repositioned duringservicing, (2) outside (contractor) personnel are at the worksite, (3) servicing or maintenance is performed by a group (rather than one specific person), and (4) shifts or personnel changes occur during servicing or maintenance.
Testing or positioning of machines. OSHA allows the temporary removal of locks or tags and the reenergization of the machine or equipment ONLY when necessary under special conditions -- for example, when power is needed for the testing or positioning of machines, equipment, or components. The reenergization must be conducted inaccordance with the sequence of the following steps:
(1) Clear the machines or equipment of tools and materials,
(2) Remove employees from the machines or equipment area,
(3) Remove the lockout or tagout devices as specified,
(4) Energize and proceed with testing or positioning, and
(5) Deenergize all systems, isolate the machine or equipment from the energy source, andreapply lockout or tagout devices as specified.
Outside personnel (contractors.) The onsite employer and the outside employer mustinform each other of their respective lockout or tagout procedures. Each employer mustensure that his or her personnel understand and comply with all restrictions and/or prohibitions of the other employer's energy control program.
Group lockout or tagout. When servicing and/or maintenance is performed by a crew,craft, department or other group, they must utilize a procedure which affords theemployees a level of protection equivalent to that provided by the implementation of apersonal lockout or tagout device.
Shift operations. During shift operations either maintain continuous control of theenergy-isolating devices or require that the oncoming shift verify deenergization andlockout/tagout.
The following paragraphs discuss other OSHA standards and programs that may beapplicable or of interest to the employers covered by the lockout/tagout rule.
Glossary
Affected employee - An employee who performs the duties of his or her job in an area inwhich the energy control procedure is implemented and servicing or maintenanceoperations are performed. An authorized employee and an affected employee may be thesame person when the affected employee's duties also involve performing maintenance or
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service on a machine or equipment that must be locked or a tagout system implemented.An effected employee does not perform servicing or maintenance on machines or equipment and, consequently, is not responsible for implementing the energy controlprocedure. An affected employee becomes an "authorized" employee whenever he or sheperforms servicing or maintenance functions on machines or equipment that must be
locked or tagged.
Authorized employee - An employee who performs servicing or maintenance onmachines and equipment. Lockout or tagout is used by these employees for their self protection.
Capable of being locked out - An energy-isolating device is considered capable of beinglocked out if it meets one of the following requirements:
It is designed with a hasp to which a lock can be attached;
It is designed with any other integral part through which a lock can be affixed;
It has a locking mechanism built into it; or
It can be locked without dismantling, rebuilding, or replacing the energy isolating deviceor permanently altering its energy control capability.
Energized - Machines and equipment are energized when (1) they are connected to anenergy source or (2) they contain residual or stored energy.
Energy-isolating device - Any mechanical device that physically prevents the
transmission or release of energy. These include, but are not limited to, manually-operated electrical circuit breakers, disconnect switches, line valves, and blocks.
Energy source - Any source of electrical, mechanical, hydraulic, pneumatic, chemical,thermal, or other energy.
Energy control procedure - A written document that contains those items of information an authorized employee needs to know in order to safely control hazardousenergy during servicing or maintenance of machines or equipment. (A morecomprehensive explanation is provided elsewhere in this booklet.)
Energy control program - A program intended to prevent the unexpected energizing or the release of stored energy in machines or equipment. The program consists of energycontrol procedure(s), an employee training program, and periodic inspections.
Lockout - The placement of a lockout device on an energy-isolating device, inaccordance with an established procedure, ensuring that the energy-isolating device andthe equipment being controlled cannot be operated until the lockout device is removed.
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Lockout device - Any device that uses positive means such as a lock, either key or combination type, to hold an energy-isolating device in a safe position, therebypreventing the energizing of machinery or equipment. When properly installed, a blank flange or bolted slip blind are considered equivalent to lockout devices.
Tagout - The placement of a tagout device on on energy-isolating device, in accordancewith an established procedure, to indicate that the energy-isolating device and theequipment being controlled may not be operated until the tagout device is removed.
Tagout device - Any prominent warning device, such as tag and a means of attachment,that can be securely fastened to an energy-isolating device in accordance with anestablished procedure. The tag indicates that the machine or equipment to which it isattached is not to be operated until the tagout device is removed in accordance with theenergy control procedure.
Footnote(1) The following OSHA standards currently contain lockout/tagout-relatedrequirements: 29 CFR Parts 1910.146 - Confined Space; 1910.178 - Powered IndustrialTrucks; 1910.179 - Overhead and Gantry Cranes; 1910.181 - Derricks; 1910.213 -Woodworking Machinery; 1910.217 - Mechanical Power Presses; 1910.218 - ForgingMachines; 1910.252 - Welding, Cutting and Brazing; 1910.261 - Pulp, Paper andPaperboard Mills; 1910.262 - Textiles; 1910.263 - Bakery Equipment; 1910.265 -Sawmills; 1910.272 - Grain Handling; 1910.305 - Wiring Methods, Components, andEquipment; 1910.333 - Selection and Use of Work Practices. Note: 1910.147(a)(1)(ii)(c)states that electric utilization installations are not covered.(Back to Text) Footnote(2) See glossary and section on "Employee Training" in this information.(Back to Text)
Footnote(3) See 29 CFR Part 1910.147(d) for the detailed requirements and language of the OSHA standard.(Back to Text)
