How to Avoid the Top LOTO Violations

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How to Avoid the Top 5 LOTO Violations
by Karen

The control of hazardous energy regulation, commonly known as lockout/tagout (LOTO), refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities. This energy can take the form of electrical, mechanical, hydraulic, pneumatic, chemical, thermal or any other type of energy.

Approximately 3 million workers service equipment and face the risk of injury if LOTO is not properly implemented. According to the Occupational Safety and Health Administration (OSHA), compliance with the LOTO standard [29 CFR 1910.147] prevents an estimated 120 fatalities and 50,000 injuries each year. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation.

Some ares of the LOTO standard are cited more frequently than others. Let’s take a closer look at the violations and how you can avoid a citation:
1. Lack of a Program

“The employer shall establish an energy control program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup, or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative” [1910.147(c)(1)].

How to avoid this citation: Develop a written LOTO program that includes procedures and relevant plant safety products to protect employees from the potentially dangerous effects of hazardous energy. Some of the problems of hazardous energy include accidental startups, electric shock and disabling injuries and death. These accidents are usually the result of someone taking a shortcut when servicing a piece of machinery. They occur when a worker doesn’t understand the equipment or maintenance procedures. A LOTO program lays the groundwork for preventing these types of accidents.

2. No Energy Control Procedures

“Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section” [1910.147(c)(4)(i)].

How to avoid this citation: You must develop a LOTO procedure that covers the following:

How to prepare for and perform the shutdown

How to isolate the equipment

How to apply and remove lockout devices

How to safely release stored energy to assure that a zero-energy state exists

How to verify that the machine or equipment is isolated from its energy supplies

Exception: You do not need to document the required procedure for a particular machine or piece of equipment when all of the following elements exist:

The machine or equipment has no potential for stored or residual energy or re-accumulation of stored energy after shutdown which could endanger employees

The machine or equipment has a single energy source which can be readily identified and isolated

The isolation and locking out of that energy source will completely de-energize and deactivate the machine or equipment

The machine or equipment is isolated from that energy source and locked out during servicing or maintenance

A single lockout device will achieve a locked-out condition

The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance

The servicing or maintenance does not create hazards for other employees

The employer, in utilizing this exception, has had no accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance

3. Untrained Employees

“The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees.

“The training shall include the following:

Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace and the methods and means necessary for energy isolation and control.

Each affected employee shall be instructed in the purpose and use of the energy control procedure.

Other employees (those whose work activities are or may be in an area where energy control procedures may be utilized) must be instructed about the procedure and about the prohibition relating to attempts to restart or reenergize machines or equipment that are locked out or tagged out” [1910.147(c)(7)(i)].

How to avoid this citation: You must identify and differentiate between authorized and affected employees. Authorized employees are those who physically lock or tag out equipment for servicing or maintenance. Note that these individuals are not necessarily the people who normally operate the equipment. Affected employees are typically those whose job requires them to operate equipment subject to LOTO.

4. Irregular or No Inspections

“The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed” [1910.147(c)(6)(i)].

How to avoid this citation: An authorized employee, other than one who is doing the energy control procedure being inspected, must complete an audit. Each audit must be documented. The periodic inspections must contain at least two components:

A visual observation of each energy control procedure

A review of lockout procedures with all the authorized employees who use the procedure (authorized employees performing the procedure as part of the inspection)

Each energy control procedure must be separately inspected at least annually to ensure that the energy control program is being properly implemented. Energy control procedures used less than once a year need to be inspected each time they are used. Machines and equipment with a similar magnitude of hazardous energy and controls can be grouped and inspected by the type of procedure, if all of the procedures in the grouping have the same or similar:

Intended machine/equipment use

Procedural steps for shutting down, isolating, blocking and securing machines or equipment

Procedural steps for the placement, removal and transfer of the LOTO devices and the responsibility for them

Requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other control measures

The inspector must be able to determine whether the inspected procedures are adequate, understood and followed by employees.

5. Inadequate Procedures

“The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance” [1910.147(c)(4)(ii)].

How to avoid this citation: You must have the following information on-hand for procedures:

Statement of intended use

Steps for shutting down machines or equipment to control hazardous energy

Machine and equipment testing requirements to determine and verify the effectiveness of LOTO devices and other energy control measures
TAGS: Audits and Inspections

Karen

Karen D. Hamel CSP, CET, WACH, is a regulatory compliance professional, trainer and technical writer. She has more than 25 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 200 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Certified Environmental health and Safety Trainer (CET), Walkway Auditor Certificate Holder (WACH), OSHA-Authorized Outreach Trainer for General Industry, Community Emergency Response Team (CERT) trainer and hazmat technician. She serves on the Blair County, PA LEPC. Her specialties include a wide variety of environmental, safety, emergency response, risk management, DOT and NIMS topics. She conducts trainings and seminars at national conferences and webinars for several national organizations. For regulation or product information, we can be reached at 1-800-HOT-HOGS (468-4647) or by email at xtechnical@newpig.com.

2 Comments

Andrew moormansays:
07/21/2017 at 10:46 am Reply
Yes I have a question when we arrived on the job site the unit was shut down and loto by the plant official and the unit operators. We knew of the lock out tag out process but we were installing walls on the shute of a log debarker do we require to be locked out tagged out if were installing new materials on it? And also we were on a 10 hour shift and most of the other contractors were out there are on a 12 hr shift do we require a separate lockout box cause we were on a shorter shift. One more question does crane operators require to lock out on that unit.
- Karensays:
  07/25/2017 at 8:24 pm Reply
  Hi Andrew, great questions!
  
  The purpose of OSHA’s Lockout Tagout (LOTO) standard is prevent injuries to anyone who is servicing or maintaining machinery or equipment that could “unexpectedly energize” or release stored energy. It’s important to note that LOTO applies to all forms of hazardous energy including electrical, hydraulic, pneumatic, mechanical, chemical and thermal.
  
  If installing new materials on a piece of equipment could potentially put someone in harm’s way, the standard applies. Even though the possibility may seem remote, locking the machinery out during the entire installation process is still required if there is the potential for harmful energy.
  
  When multiple people are working on the same system, everyone who is working in or around the machinery needs to have their own lock. I have seen situations where there are more than 30 locks on a system.
  
  Hasps can be added to a lockout box if there aren’t enough spots for everyone’s lock. But, with very few exceptions, everyone should be locked out at the same point. You really shouldn’t have two separate boxes unless they are both locked to the same lockout point. It’s a good idea for each person to put their name and phone number on their padlock so that they can be contacted in the event that they forget to take their lock off of the box or hasp at the end of the job.
  
  If you have one shift that works longer than the other, perhaps the employees on the longer shift put their locks on the box and the employees on the shorter shift put their locks on a hasp. This arrangement could also be a good check to ensure that everyone from the first shift has safely made it out of the area.
  
  Cranes have mechanical energy. So, crane operators who are involved in constructing, installing, setting up, adjusting, inspecting, modifying and maintaining and/or servicing machines or equipment would fall under the LOTO standard [29 CFR 1910.147(b)].
  
  I hope this information helps! Please let me know if you have any other questions.
  
  Best,
  Karen

1. Lack of a Program

2. No Energy Control Procedures

3. Untrained Employees

4. Irregular or No Inspections

5. Inadequate Procedures

Karen

2 Comments

Andrew moormansays:

Karensays:

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