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Lock Out & Tag Out (LOTO) Jay Jamali CSP, CHMM, CHCM EHS Director Enviro Safetech 408-943-9090.

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Presentation on theme: "Lock Out & Tag Out (LOTO) Jay Jamali CSP, CHMM, CHCM EHS Director Enviro Safetech 408-943-9090."— Presentation transcript:

1 Lock Out & Tag Out (LOTO) Jay Jamali CSP, CHMM, CHCM EHS Director Enviro Safetech

2 Slide-2 3/08 Regulations Cal-OSHA regulates the control of hazardous energy under Title 8 of the California Code of Regulations (CCR) General Industry Safety Orders (GISO) section –The Control of Hazardous Energy for the Cleaning, Repairing, Servicing, Setting-Up, and Adjusting Operations of Prime Movers, Machinery and Equipment, Including Lockout/Tagout.

3 Slide-3 3/08 Regulations Fed-OSHA regulates the control of hazardous energy under 29 CFR (Code of Federal Regulations) General Industry Section –Appendix A of 29CFR serves as a non-mandatory guideline to assist in complying with the requirements of the standard, as well as to provide other helpful information. –Nothing in the appendix adds to or detracts from any of the requirements of the standard.

4 Slide-4 3/08 Regulations The Fed standard does not apply to: –Construction, –Agriculture and –Maritime employment; –Installations under the exclusive control of electric utilities for the purpose of power generation, transmission and distribution, including related equipment for communication or metering; and –Oil and gas well drilling and servicing.

5 Slide-5 3/08 Regulations Fed-OSHA has issued a new (2/08) enforcement policy and Inspection procedure for OSHA personnel performing inspection activity related to the control of hazardous energy (CPL ). –This instruction cancels the September 11, 1990 OSHA Instruction, STD Significant modifications include: –Changes in the instruction format necessitated by the OSHA Directive System (ADM ); –Addition of Compliance Officer Safety guidelines; –Inclusion of Citation Examples and additional guidance regarding Affirmative Defenses; –Incorporation of compliance assistance flowcharts;

6 Slide-6 3/08 Regulations –Inclusion of additional guidance on the minor servicing exception, specific energy control procedures, periodic inspections, and unexpected energization; –Inclusion of additional information and guidance on Alternative Methods to Lockout/Tagout (LOTO); –Inclusion of general reference material for information pertinent to hazardous energy control, including governmental, industry and national consensus standards; and –Addition of vehicle repair and maintenance standards and practices, including relevant Internet links, to assist employers engaged in these activities with hazardous energy control.

7 Slide-7 3/08 Fed vs State If the state regulation is more stringent than Federal follow state. Enviro Safetech recommends compliance with Fed-OSHA rather than state regulation if Fed-OSHA is more stringent than the state regulation.

8 Slide-8 3/08 ANSI Standard The American National Standard Institute (ANSI) has issued a guideline (not enforceable unless adopted by OSHA): –Control of hazardous energy Lockout/Tagout and Alternative methods –ANSI/ASSE Z –Approved 7/03 –Published 4/04.

9 Slide-9 3/08 Tasks Needing LOTO The following activities may require LOTO: –Inspection –Preventative Maintenance –Repair –Calibration –Installation –Adjustment

10 Slide-10 3/08 Energy Sources The energy sources to be LOTOd: –Electrical –Thermal –Gravity –Chemical –Springs –Hydraulic –Compressed Gas

11 Slide-11 3/08 Hazards Hazards associated with failure to LOTO: –Being struck –Being crushed

12 Slide-12 3/08 Hazards –Being Pinched –Being Cut

13 Slide-13 3/08 Hazards –Being burned Thermally or Chemically –Being electrocuted

14 Slide-14 3/08 Scope The Cal-OSHA regulation applies to the cleaning, repairing, servicing, setting-up and adjusting of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. –Cleaning, repairing, servicing and adjusting activities shall include unjamming prime movers, machinery and equipment.

15 Slide-15 3/08 Definitions Affected employee: Is an employee whose job requires them to operate or use equipment on which cleaning, repairing, servicing, setting-up or adjusting operations are being performed under LOTO, or whose job requires the employee to work in an area in which such activities are being performed under LOTO. Authorized employee: Is a qualified person who locks out or tags out specific equipment in order to perform cleaning, repairing, servicing, setting-up, and adjusting operations on that machine or equipment.

16 Slide-16 3/08 Definitions Energy isolating device: –A mechanical device that physically prevents energy flow such as: Manually operated electrical circuit breaker Disconnect switch Line valve –Push buttons, selector switches and other control circuit type devices are not energy isolating devices.

17 Slide-17 3/08 Compliance Written Program (hazardous energy control program) –Equipment specific LOTO procedures Training Extension Equipment Locking Tagging Blocking Live Operations Periodic Inspection Contractors

18 Slide-18 3/08 Regulation Overview If the machinery or equipment must be capable of movement in order to perform the specific task, the employer shall minimize the hazard by providing and requiring the use of extension tools (eg., extended swabs, brushes, scrapers) or other methods to protect employees from injury due to such movement. –Employees shall be made familiar with the safe use and maintenance of such tools, methods or means, by thorough training.

19 Slide-19 3/08 Regulation Overview Equipment that have lockable controls or readily adaptable to lockable controls shall be locked out or positively sealed in the “off” position during repair work and setting-up operations. –Equipment that do not have lockable controls or readily adaptable to lockable controls shall be de-energized or disconnected from its source of power, or other action which will effectively prevent the equipment from inadvertent movement or release of stored energy. –LOTO tags shall be placed on the controls of the equipment during repair work and setting-up operations.

20 Slide-20 3/08 Exemption LOTO is not required: –During minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection. –Work on cord and plug-connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the work.

21 Slide-21 3/08 HECP A written Hazardous Energy Control Program (HECP) shall be developed and utilized by the employer when employees are engaged in the cleaning, repairing, servicing, setting-up or adjusting of equipment. The HECP must clearly and specifically outline: –Scope, –Authorization, –Rules, –Means to enforce compliance

22 Slide-22 3/08 HECP –Employee training, –Periodic inspections to ensure LOTO procedures are being followed. –Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy; –A specific statement of the intended use of the procedure;

23 Slide-23 3/08 HECP –Specific procedural steps for the placement, removal and transfer of LOTO devices and the responsibility for them; –Specific requirements for testing equipment to determine and verify the effectiveness of LOTO devices, and other energy control measures. –Protective materials and hardware.

24 Slide-24 3/08 Equipment Specific The employer's HECP shall include separate procedural steps for the safe LOTO of each piece of equipment affected by the HECP. The procedural steps for the safe LOTO of equipment may be used for a group of equipment if: –The operational controls named in the procedural steps are configured in a similar manner, and –The locations of disconnect points (energy isolating devices) are identified, and –The sequence of steps to safely LOTO the equipment are similar. No procedure is needed if the equipment has a single energy supply that is readily identified and isolated and has no stored or residual hazardous energy.

25 Slide-25 3/08 LOTO Devices The employer shall provide LOTO tags, locks or other similarly effective means which may be required for cleaning, servicing, adjusting, repair work or setting-up operations. LOTO Devices shall have means by which they can be readily secured to the equipment controls. Tagout device attachment means shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds. LOTO tags are not required where an employer has a uniform system with unique and personally identifiable locks designed for LOTO, that are placed on the source of energy.

26 Slide-26 3/08 Training Authorized employees shall be trained on the HECP and on the hazards related to performing activities required for cleaning, repairing, servicing, setting-up and adjusting prime movers, machinery and equipment. –Each affected employee shall be instructed in the purpose and use of the energy control procedure. –All other employees whose work operations may be in an area where energy control procedures may be utilized, shall be instructed about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out. Such training shall be documented.

27 Slide-27 3/08 Repetitive Process Eqmt On repetitive process equipment, such as numerical control machines, which require power or current continuance to maintain indexing and where repair, adjustment, testing, or setting-up operations cannot be accomplished with the prime mover or hazardous energy source disconnected, such operations may be performed under the following conditions: –The operating station where the machine may be activated must at all times be under the control of a qualified operator. –All participants must be in clear view of the operator or in positive communication with each other.

28 Slide-28 3/08 Repetitive Process Eqmt –All participants must be beyond the reach of machine elements which may move rapidly and present a hazard to them. –Where machine configuration or size requires that the operator leave his control station to install tools, and where machine elements exist which may move rapidly if activated, such elements must be separately locked out by positive means. –During repair procedures where mechanical components are being adjusted or replaced, the machine shall be de-energized or disconnected from its power source. –“Participant” shall mean any other person(s) engaged in the repair, adjustment, testing, or setting up operation in addition to the qualified operator or craftsman having control of the machine operating station.

29 Slide-29 3/08 Periodic Inspection The employer shall conduct a periodic inspection of the HECP (Enviro Safetech recommends annual) to ensure that the procedure and the requirements of the LOTO regulation are being followed. –The periodic inspection shall be performed by an authorized employee other than the one(s) utilizing the HECP being inspected.

30 Slide-30 3/08 Periodic Inspection Periodic inspection shall include a review between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected. The employer shall certify that the periodic inspections have been performed.

31 Slide-31 3/08 Periodic Inspection The certification shall identify the: –Equipment on which the HECP was being utilized, –Date of the inspection, –Employees included in the inspection, and –Person performing the inspection.

32 Slide-32 3/08 Contractors Whenever outside servicing personnel are to be engaged in LOTO activities, the on-site employer's LOTO procedures shall be followed.

33 Slide-33 3/08 Federal Requirements Fed-OSHA 29 CFR has additional requirements as compared to Cal-OSHA.

34 Slide-34 3/08 Regulation Overview Normal production operations are not covered by this standard Servicing and/or maintenance which takes place during normal production operations is covered only if: –An employee is required to remove or bypass a guard or other safety device; or –An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.

35 Slide-35 3/08 Lock Out vs Tag Out If an energy isolating device is capable of being locked out, it shall be locked out unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection. If an energy isolating device is not capable of being locked out, the employer shall utilize a tagout system which must be detailed in the written ECP.

36 Slide-36 3/08 Tagout Only The employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program with such additional safety measures such as –The removal of an isolating circuit element, –Blocking of a controlling switch, –Opening of an extra disconnecting device, or –The removal of a valve handle to reduce the likelihood of inadvertent energization.

37 Slide-37 3/08 Tagout Only When a tagout device is used on an energy isolating device which is capable of being locked out: –The tagout device shall be attached at the same location that the lockout device would have been attached,

38 Slide-38 3/08 Tagout Training When only tagout systems are used, employees shall also be trained in the following limitations of tags: –Tags are essentially warning devices affixed to energy isolating devices, and do not provide the physical restraint on those devices that is provided by a lock. –When a tag is attached to an energy isolating means, it is not to be removed without authorization of the authorized person responsible for it, and it is never to be bypassed, ignored, or otherwise defeated. –Tags must be legible and understandable by all authorized employees, affected employees, and all other employees whose work operations are or may be in the area, in order to be effective.

39 Slide-39 3/08 Tagout Training –Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace. –Tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall ECP. –Tags must be securely attached to energy isolating devices so that they cannot be inadvertently or accidentally detached during use.

40 Slide-40 3/08 Retraining Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the ECP. Additional retraining shall also be conducted whenever a periodic inspection 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 ECP.

41 Slide-41 3/08 Retraining The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary. The employer shall certify that employee training has been accomplished and is being kept up to date. –The certification shall contain each employee's name and dates of training.

42 Slide-42 3/08 Training The authorized employee training shall include recognition of 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.

43 Slide-43 3/08 Training Some companies are using computer based training or online training for LOTO. Recommend supplementing said training with site specific follow up training on the site HECP.

44 Slide-44 3/08 Training The use of videos in the beginning of the LOTO initial or refresher training is industry practice. Recommend using a different video for refresher training. Certification training is usually 2 hours and refresher is one hour.

45 Slide-45 3/08 Training Some companies issue badges or stickers to authorized employees to help identify employees authorized to perform LOTO.

46 Slide-46 3/08 New Equipment After January 2, 1990, whenever replacement or major repair, renovation or modification of a equipment is performed, and whenever new equipments are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device.

47 Slide-47 3/08 Group LOTO When servicing and/or maintenance is performed by a crew, craft, department or other group, they shall utilize a procedure which affords the employees a level of protection equivalent to that provided by the implementation of a personal LOTO device.

48 Slide-48 3/08 Group LOTO Group LOTO devices shall be used in accordance with but not necessarily limited to, the following: –Primary responsibility is vested in an authorized employee for a set number of employees working under the protection of a group LOTO device (such as an operations lock); –Provision for the authorized employee to ascertain the exposure status of individual group members with regard to the LOTO of the machine or equipment and

49 Slide-49 3/08 Group LOTO –When more than one crew, craft, department, etc. is involved, assignment of overall job-associated LOTO control responsibility to an authorized employee designated to coordinate affected work forces and ensure continuity of protection; and –Each authorized employee shall affix a personal LOTO device to the group LOTO device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained.

50 Slide-50 3/08 Shift/Personnel Changes Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of LOTO protection, including provision for the orderly transfer of LOTO device protection between out-going and oncoming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.

51 Slide-51 3/08 Contractors Whenever outside servicing personnel are to be engaged in operations requiring LOTO, the on-site employer and the outside employer shall inform each other of their respective LOTO procedures. The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer's ECP.

52 Slide-52 3/08 General LOTO General LOTO procedure for equipment that do not require an equipment specific LOTO procedure shall be done in the following sequence: –Notify employees. –Prepare for shutdown. –Equipment shutdown. –Equipment isolation. –LOTO device application.

53 Slide-53 3/08 General LOTO –Check for stored energy. –Verification of isolation. –Perform work. –Release from LOTO. –Notify employees Recommend the use of a general checklist to remind employees of the proper sequence and list of tasks associated with general LOTO procedures.

54 Slide-54 3/08 Notification Affected employees shall be notified by the authorized employee of the application and removal of LOTO devices. –Notification shall be given before the controls are applied, and after they are removed from the equipment.

55 Slide-55 3/08 Device Removal LOTO devices shall be removed by the employee who applied the device. –When the authorized employee who applied the LOTO device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures and training for such removal have been developed, documented and incorporated into the employer's energy control program. –The employer shall demonstrate that the specific procedure provides equivalent safety to the removal of the device by the authorized employee who applied it.

56 Slide-56 3/08 Device Removal The specific procedure for device removal by a second party shall include at least the following elements: –Verification by the employer that the authorized employee who applied the device is not at the facility, –Making all reasonable efforts to contact the authorized employee to inform him/her that their LOTO device has been removed; and –Ensuring that the authorized employee has this knowledge before he/she resumes work at that facility.

57 Slide-57 3/08 Equipment Specific LOTO Equipment specific LOTO procedure are required for the following type of equipment: –Potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees (example equipment has a capacitor in it); –Has more than one energy source or the source cannot be readily identified and isolated;

58 Slide-58 3/08 Equipment Specific LOTO –The equipment is not isolated from the energy source and locked out during servicing or maintenance (equipment is live or hot) ; –More than one LOTO device is needed to lock out the equipment; –The lockout device is not under the exclusive control of the authorized employee performing the servicing or maintenance; –The servicing or maintenance creates hazards for other employees; or –An accident involving the unexpected activation or reenergization of the equipment has occurred during servicing or maintenance.

59 Slide-59 3/08 Equipment Specific LOTO Enviro Safetech recommends: –Posting the equipment specific procedure at the equipment. –Developing a equipment specific LOTO kit that contains all the LOTO devices necessary to LOTO the equipment. –Performing a site survey to identify equipments that require equipment specific LOTO procedures. Recommend keeping an inventory of equipment evaluated. Recommend equipments to be assigned and tagged with a unique number so that the identity of each equipment is easily known.

60 Slide-60 3/08 Equipment Specific LOTO Interview the equipment users to determine which tasks require LOTO. –Do not assume anything, –Focus on tasks done by operators, maintenance, contractor and engineers, –Review the manual for the equipment;

61 Slide-61 3/08 Equipment Specific LOTO Identify all energy sources and locate all energy isolating devices. –Attaching a form of identification to or near each energy isolating device is recommended.

62 Slide-62 3/08 Equipment Specific LOTO Take a set of all types of LOTO devices with you and attempt to apply it to the energy isolating device. –Attempt to apply the LOTO device because both the energy isolating devices and LOTO devices come in many shapes, sizes and configurations which sometimes limits which LOTO device can fit. –Recommend marking each LOTO device with a part number to simplify ordering LOTO devices and selecting them in the field.

63 Slide-63 3/08 Equipment vs Task Specific Some equipment are so complicated that writing a equipment specific procedure would be too daunting a task A task specific equipment specific LOTO procedure is recommended Task specific LOTO procedure would select a specific task requiring LOTO and writing the equipment specific procedure focused on said task.

64 Slide-64 3/08 Equipment Specific LOTO Some companies have manufacturing personnel develop the equipment specific LOTO procedure for their equipment according to a set guideline which is then reviewed by the Safety department. –Others use a contractor or the Safety department develops the procedure. After writing the equipment specific LOTO procedure have the equipment owner review the procedure to make sure they can live with it. –Get them to sign the procedure.

65 Slide-65 3/08 Equipment Specific LOTO We recommend the format of the equipment specific procedures be standardized. Recommend the use of digital photos in the procedure to identify the location of the energy controlling devices.

66 Slide-66 3/08 Internet reference –Subject index L, Lock Out Tag Out –http://www.osha.gov/SLTC/controlhazardousenergy /index.htmlhttp://www.osha.gov/SLTC/controlhazardousenergy /index.html –Access the regulation and enforcement directive from this page


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