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A Presentation of the SPI-OSHA Alliance

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1 A Presentation of the SPI-OSHA Alliance
Lockout/Tagout for Injection Molding Control of Hazardous Energy The Society of the Plastics Industry. Inc. (SPI) and OSHA formed an Alliance in the fall of 2002 in order to help employers in the plastics industry provide safer working environments in their plants. This is a national Alliance, signed with Federal OSHA. As you may know, there are 22 State Plan States that run their own occupational safety and health programs for general industry employers. The rest of the states are covered by Federal OSHA. Although most of the State Plan States have adopted the Federal OSHA Standards, there may be some differences (e.g., California, Michigan) and this course is based on Federal OSHA standards. This course on Machine Guarding and Lockout/Tagout (LOTO) was created by a dedicated team, consisting of experts from OSHA and industry. This is a train-the-trainer course—that is, these training modules not only consolidate all the critical information you need on machine guarding and LOTO, but also prepare you to train employees at your worksite. The Alliance would like to hear back from you—not only about how well these tools work for you and how many people you train, but also about ideas you may have for other areas that we can work together on to make a safer workplace in our industry. Please send your comments to Susan Howe, SPI, 1667 K Street, N.W. Suite 1000, Washington, D.C or via at Thank you. Third Edition – June 2006 A Presentation of the SPI-OSHA Alliance The Society of the Plastics Industry, Inc.

2 1910.147 The Control of Hazardous Energy a.k.a. Lockout/Tagout (LOTO)
The specific practices and procedures necessary to disable machinery and equipment so that employees performing service and maintenance activities are protected Plastics processors are the most frequently cited industry under OSHA's Lockout/Tagout Standard. There is some confusion when referring to the requirements we are going to discuss as LOTO, because this implies that locks and keys are the only control methods for hazardous energy. But what about other energy such as gravity, chemicals, thermal? We should remember that this is the standard for controlling hazardous energy, other than electrical shock, which is covered by OSHA's Electrical Safety Standard, 29 CFR , Selection and use of work practices. Find more about workplace statistics and inspection data on OSHA’s Web site at: Find out more about the standard at

3 The Purpose of LOTO Prevent injuries from the unexpected startup or release of stored energy Reduce the number of fatalities and injuries Establish a program and procedures for controlling hazardous energy The purpose of this standard is to prevent an injury from unexpected start-up or release of stored energy. The standard does not kick in unless the worker is performing service and maintenance in a certain area of a machine where he/she could be injured from unexpected start-up or release of stored energy. For example, if a worker is making adjustments or cleaning parts of a machine away from pinch points, mold areas, hot surfaces, etc., Lockout would not apply.

4 Where to Begin? Job Safety Analysis (JSA) Develop Procedures Verify
Train Audit Today, many companies use the Job Safety Analysis/Job Hazard Analysis Process as an effective means of helping reduce incidents, accidents, and injuries in the workplace. It is an excellent tool to use during new employee orientations and training and can also be used to investigate "near misses" and accidents. Job safety analysis (JSA) is part of many existing accident prevention programs. In general, JSA breaks a job into basic steps, and identifies the hazards associated with each step. The JSA also prescribes controls for each hazard. A JSA is a chart listing these steps, hazards, and controls. There are many commercial vendors of Job Safety Analysis software. You also may want to consider performing a risk assessment such as ANSI B11.TR Risk Assessment and Risk Reduction - A Guide to Estimate, Evaluate and Reduce Risks Associated with Machine Tools.

5 Preventing Unexpected Startup or Release of Energy
Energy isolation: Minimize potential for inadvertent activation and/or release of stored energy Ensure power to the machine is isolated and locked at control points Use a method that cannot readily be removed, bypassed, overridden or otherwise defeated The entire OSHA Lockout/Tagout Standard is based on the practices and procedures that are necessary to disable and isolate machines or equipment from the unexpected release of hazardous energy. The employer’s primary tool for providing protection under the standard is the energy isolating device, which is the physical device that prevents the transmission or release of stored energy.

6 Common Types of Energy Used in Injection Molding
Electrical Mechanical Hydraulic Chemical Pneumatic Thermal Gravity You should consider all of the listed types of energy when performing your hazard analysis. Hydraulic includes water pressure and other fluid power systems Pneumatic includes all systems with compressed gases. Please consider all of the different types of energy from the list above that might be found in your particular manufacturing facility.

7 Definitions Servicing and/or maintenance - activities where employees may be exposed to unexpected start-up or release of hazardous energy including: Construction Installing and setting up Adjusting, inspecting, modifying Maintaining and/or servicing equipment Lubricating, cleaning or unjamming Tool changes or adjustments As you can tell, this standard covers many activities that may be performed by employees other than those authorized to perform maintenance. Regardless of an employee’s job title, OSHA's LOTO Standard applies when the listed servicing or maintenance tasks are being performed and when there is potential for unexpected start-up or release of stored energy. In addition, employees performing these tasks must be trained and authorized under the OSHA's LOTO Standard.

8 Definitions (cont’d) Set-up - Work to prepare a machine to perform its normal production operation Lockout – Placement of lockout device on an energy isolating device Lockout device – Device that uses a physical means to prevent energizing of a machine or equipment

9 Definitions (cont’d) Energized - Connected to an energy source, or containing residual or stored energy Energy isolating device - A mechanical device that physically prevents the transmission or release of energy Push buttons, selector switches and other control circuit devices are not energy isolating devices Push buttons, selector switches and other control circuit devices are not energy isolating devices. Control circuit devices only interrupt the control circuit. They do not isolate the energy sources. They will not prevent several types of potential risks, which vary with machine and circuit design, such as the following examples: Motors, pumps and other equipment can restart from shorts in the electrical system control circuits Switches can fail and go unnoticed Employees may start up machines without knowing that other employees are in a dangerous area.

10 Common Causes of Accidents
Failure to identify risk Employees working outside of job description Inadequate training and/or comprehension Pressure to meet production goals Feeling they can do the task after watching someone else do it The speaker should paraphrase the points listed in the slide.

11 LOTO applies when: Employees are performing servicing and maintenance, and there is a potential for injury from unexpected start-up or release of stored energy Service and maintenance that takes place during normal production, if employee: Must remove or bypass a guard or safety device; or Must place any part of their body into the danger zone Normal production operations are covered by OSHA's Machine Guarding Standards and are not part of Service and Maintenance. The danger zone includes the point of operation or any other area where there is exposure to hazardous energy sources. Let's consider the service and maintenance that takes place, such as clearing a major jam, which causes a temporary interruption of normal production. Assume this is going to require removing jammed parts or product and making adjustments the machine. The employee will probably not have to remove or bypass a guard, but will probably have to place their hands/arms into the point of operation area. Although this takes place during production, this type of un-jamming would in most cases not be considered routine and repetitive, and OSHA's LOTO Standard would apply. However, if this same employee could use special tools to remove this product, which would keep his body out of the Danger Area, OSHA's LOTO Standard would not apply. Additional information can be found at: 29 CFR (a)(2)(ii)(B)

12 Exception to LOTO Minor servicing activities that take place during normal production when alternative effective protection is used The first thing to consider when determining an exception to LOTO is that the activities must be minor and have to take place during normal production. By definition, set-up work (except minor tool changes and adjustments) is not production. Some lubricating, cleaning and un-jamming activities may meet the exception criteria. Determination of LOTO application should be made on a case-by-case basis. The key thing to remember is that when certain servicing and maintenance tasks meet all the exception criteria, and LOTO is not required, alternative effective protection must be in place.

13 Minor Servicing During Normal Production Operations
Routine Repetitive Integral to the use of the equipment for production Requires that the work is performed using measures which provide alternative effective protection. In addition to the service and maintenance taking place during production with alternative effective protection, the service and maintenance must be routine, repetitive and integral to the production process. If the decision is made that a job is a minor servicing activity that takes place during normal production when alternative effective protection is used, it may meet the exception criteria. Employers are responsible for making this determination on a case by case basis. For further information, see OSHA's Subpart O - Machinery and Machine Guarding Standard, 29 CFR

14 Alternative effective protection such as:
Interlocked gates and barriers Remote lubricators or other remote devices Other effective guarding devices as described in OSHA's Subpart O and the most current ANSI B151.1 standard

15 Accident #1 Amputation of Finger
A setup person suffered an amputation of a finger when it was caught in a pinch point while making adjustments to a knockout mechanism. We are providing examples of recent injection molding accidents as a training exercise to help you better understand the types of injuries that are occurring in these "risk areas", and to assist you in designing your safety programs to prevent these accidents.

16 Accident #2 Amputation of Hand
An operator's hand was amputated between the mold halves of an injection molding machine. Occasionally, the mold would open half way, and parts would stick, so he was reaching in to pull a part off. Operator was pulling at part with one hand while holding the gate open with the other hand. What's wrong with this picture? If the gates are interlocked when open, how did the mold close?

17 Accident #3 Crushing Fatality
A supervisor entered an injection molding machine while inspecting for the source of a hydraulic leak when the machine cycled. The supervisor died from massive head injuries. Two fixed guards were removed about 12 days prior to the accident. What's wrong with this picture? Where was the machine inspection report? The supervisor should have known that the guards were missing and that the machine was not to be operated without guards.

18 Accident #4 Fatality A setup person was killed when he entered the machine to remove a jammed part. The rear guard interlock had been inoperable for about 6 months. What's wrong with this picture? Where was the machine inspection report? The supervisor should have known that the guards were missing and that the machine was not to be operated without guards. Do you think the setup person would have entered the machine if he knew that the guards were missing and he would likely get killed?

19 Accident #5 Crushing Fatality
An operator crawled under the machine to pick up parts while it was operating. His head was crushed when the platen opened. What's wrong with this picture? How could this situation have been avoided? How about by using a tool to retrieve the parts?

20 Energy Control Program
Core Components of an Energy Control Program Energy control procedures for each type of machine Training and retraining to ensure employees understand the program Periodic inspection to ensure procedures are being followed ABC Co. Energy Control Program Purpose._______________________________________________________________________ Compliance with this program ______________________________________________________________________________ Sequence of Lockout (1)__________________________________________________ These are the 3 core components of the Energy Control Program. We will be discussing each one of these components in the slides that follow.

21 Energy Control Procedures
Must be specific to each type of machine and equipment you are working on Must include Statement of intended use of the procedure Steps for shutting down and securing machines and equipment Steps for placing, removing, and transferring of lockout devices Requirements for testing and verifying effectiveness of lockout devices Energy control procedures provide authorized employees with written instructions specifying how to safely control hazardous energy while performing servicing and maintenance on specific machines. The procedure must identify the type and magnitude of the hazardous energy they expect to encounter and the approved methods to control it. If the control procedures are the same for various pieces of equipment, then a single energy control procedure may be sufficient.

22 Required Training Authorized employees Affected employees
Recognition of hazardous energy sources Type and magnitude of energy in the workplace Methods for energy isolation / control Affected employees Purpose and use of energy control procedures Other employees in work area Procedures related to restarting machines Training in lockout must be provided to all employees who may be in an area where energy control procedures are used. This training must ensure that the purpose and function of the energy control program is understood and that employees gain the needed knowledge and skills to safely apply, use, and remove energy controls.

23 Retraining Requirements
Retraining is required if: Change in job assignments Change in machines Change in energy control procedures Equipment or processes present new hazards Inspections reveal deficiencies in employee's knowledge of energy control procedures Retraining must reestablish employee proficiency Retraining must 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 energy control procedures (c)(7)(iii) Additional retraining must also be conducted whenever a periodic inspection under paragraph (c)(6) of this section 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 control procedures.

24 Periodic Inspections Performed at least annually
Conducted by authorized employees Intended to correct inadequacies identified in program Certified Employer is responsible for conducting inspections to ensure that the procedures and the lockout standard are being followed. Inspections are conducted by authorized employees other than the one(s) utilizing the energy control procedure being inspected (c)(6)(i)(A) An authorized employee is a person who locks out the equipment or machine in order to perform service and maintenance on it.

25 Certification Requirements
Identification of equipment or machinery Date of inspection Names of employees involved in the inspection Name of person(s) performing inspection

26 Application of the Energy Control Procedure (Lockout)
Prepare for shutdown Shut down equipment Isolate all energy sources Apply locks & tags Release stored energy Verify equipment isolation Perform the task Release from Lockout

27 Step 1: Prepare for Shutdown
Understand equipment hazards Notify other workers of shutdown Machinery and equipment should be shut down in an orderly manner using normal shutdown procedures.

28 Step 2: Shut down equipment
Use the normal shutdown procedures Turn all switches to OFF/Neutral

29 Step 3: Isolate all Energy Sources
Use energy isolation devices in accordance with established procedures to prevent transmission or release of energy Open breakers and disconnects Shut off or close all control valves Relieve, block or otherwise control stored or residual energy Disable all sources of energy

30 Step 4: Apply Locks & Tags
Apply locks and tags to: Valves Breakers/electrical disconnects Mechanical blocks Before applying and after removing lockout/tagout devices, the authorized employee must notify all affected employees. Blank and tag flanges Valve lockout device

31 Step 5: Release or Block all
Stored Energy Discharge capacitors Block/disconnect lines Block or release springs Block elevated parts Relieve system pressure Drain fluids Vent gases Allow system to cool (or use PPE) Apply any additional locks and tags needed

32 Step 6: Verify Equipment Isolation
Check that other workers are clear of potential hazards Check that locking devices are secure Attempt normal startup Return control to OFF/Neutral Controls to verify energy isolation

33 Step 7: Perform the Task Perform maintenance or service

34 Step 8: Release from Lockout
Ensure machinery is properly assembled and all tools removed Ensure that employees are outside of danger zones and are notified that devices are being removed Remove LOTO devices Must be removed by authorized employee who applied it The authorized employee should follow these procedures prior to removing LOTO devices and restoring energy. Exception: When authorized employee is not at the facility. All reasonable efforts must be taken to consult with that employee or otherwise determine that it is safe to remove the lockout and proceed with the scheduled tasks, and in any event to inform him/her that the LOTO device has been removed. Written procedures must be in place to remove LOTO devices applied by an employee who is not available to remove them.

35 The Job Safety Analysis Process
The Job Safety Analysis (JSA) process is a very effective means of helping reduce incidents, accidents, and injuries in the workplace. It is a multi-step process. Basic Job Steps Potential Hazards Recommended Safe Job Procedures Break the job into a sequence of steps. Each of the steps should accompany some major task. That task will consist of a series of movements. Look at each series of movement within that basic task. To complete a JSA effectively, you must identify the hazards or potential hazards associated with each step. Hazards contribute to accidents and injuries. All sources of energy must be identified. It is very important to look at the entire environment to determine every conceivable hazard that might exist. Using the Sequence of Basic Job Steps and Potential Hazards, decide what actions are necessary to eliminate, control, or minimize hazards that could lead to accidents, injuries, damage to the environment, or possible occupational illness. Each safe job procedure or action must correspond to the job steps and identified hazards. Everyone involved in implementing a job or task should be present when the JSA is written. The JSA should be reviewed, approved, and signed by the supervisor before the task is started. Understanding every job step is very important. Whenever a job step changes or a new step is introduced, the JSA must be reviewed and updated. Remember, the key reasons for completing a JSA are to encourage teamwork, to involve everyone performing the job in the process, and to elevate awareness.

36 Our sincere thanks to: United Southern Industries, Inc.
OSHA Regions V & VIII OSHA’s Office of Education and Training OSHA’s Salt Lake Technical Center Michigan OSHA The Society of the Plastics Industry, Inc. United Southern Industries, Inc., for Wayne Wilson’s time and expertise. OSHA Region V, for John Hermanson’s strong support of the Alliance goals and Jim Washam’s time and expertise. OSHA Office of Education and Training, for Cathy Cronin’s vision and leadership. OSHA’s Salt Lake Technical Center for developing the animations for this course.

37 Do You Have Any Questions?

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