Elements of a Lockout/Tagout Program 29 CFR

Elements of a Lockout/Tagout Program 29 CFR 1910.147
BWC Division of Safety & Hygiene Laura Smith Industrial Safety Consultant Specialist Mansfield Service Office P: E: Photo courtesy of BWC employee Roman Wilshanetsky 1

How to Read OSHA Standards
29 CFR (a)(1)(i) 29 Title CFR Code of Federal Regulations 1910 Part 147 Subpart (a) Subsection (1)(i)(a) Explanatory Subsection Other Titles 34 Education 40 EPA 49 DOT CFR – Administrative Laws Official compilation of federal rules and requirements Other Parts 1926 Construction 1904 Recordkeeping Other Subparts 133 Electrical 178 Forklift 1200 Hazcom 212 Machine Guarding

References OSHA Compliance Directives OSHA Instruction ANSI Standards
CPL Control of Hazardous Energy OSHA Instruction STD Electrical Safety Related Work Practices -Inspection Procedures and Interpretation ANSI Standards B Performance Criteria for Safeguarding Z Lockout/Tagout and Alternative Methods

Other Part 1910 Regulations with Lockout/tagout - Related Requirements
The following listing, taken from OSHA Instruction CPL 2.82, an OSHA guidance document on inspection procedures and compliance clarification for the Control of Hazardous Energy Sources regulation, indicates a number of OSHA regulations that currently impose lockout/tagout-related requirements. The list does not necessarily include all lockout/tagout - related OSHA 29 CFR 1910 regulations. Title of Related Regulation Regulatory Citation of Related Regulation Powered Industrial Trucks Part (g)(4) Overhead and Gantry Cranes Part (g)(5)(i)(ii)(iii), Part (l)(2)(i) ( c)(d) Derricks Part (f)(2)(i)(c), (d) Wood-working Machinery Part (a)(10), Part (b)(5) Mechanical Power Presses Part (b)(8)(i), Part (d)(9)(iv) Forging machines Part (a)(3)(iii)(iv), Part (j)(1) Welding, Cutting and Brazing Part (a)(3)(i) Pulp. Paper, & Paperboard Mills Part (c)(1), Part (p)(1) Textiles Part (c)(1), Part (p)(1) Sawmills Part (c)(13), Part (c)(26)(v) Electric Power Generation, transmission and distribution Part (d)(1)-(8), Part (m)(1)-(3). Grain Handling Part (e)(1)(ii), Part (l)(4) Electrical Part (j)(4)(ii)(A), Part (j)(4)(ii)(C)(1) Part (b)(2) Tab 3 Review how to read an OSHA standard and Cover: Tab 7 Review how Standard Interpretations work Refer to page 2-9 in book for larger view

Scope, Application & Purpose
This standard covers the servicing and maintenance 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. Establishes minimum performance requirements OSHA only provides minimum standards Many of OSHA’s standards are outdated because it takes years (as seen from the Union request of 1979) for OSHA to get new standards approved.

Does Not Cover: Construction, agriculture, maritime Power generation, transmission, distribution Electrical hazards covered in Subpart S Oil & gas well drilling and servicing Construction: OSHA will expect that construction use industry standards when performing industry type work. Electrical hazards: Use electrical standard

Standard does not apply to: Work on cord and plug connected electric equipment Exclusive Control Hot tap operations Exclusive control means that the authorized employee would be able to prevent the equipment from becoming re-energized during servicing or maintenance of that equipment. The plug is under exclusive control of the employee if it is physically in the possession of the employee, or within arms reach and in line of sight of the employee, or if the employee has affixed a LOTO device on the plug. Photo courtesy of BWC employee Roman Wilshanetsky

Normal production operations are not covered by this standard. See Subpart O – Machine Guarding. Standard applies during Servicing or Maintenance of equipment See Compliance Directive Repetitive – not defined in standard so you will need to prove to a compliance officer that, in fact, it meets their definition of “repetitive”. Examples might include clearing a jam using a tool or to lubricate the machine. Photo courtesy of BWC employee Roman Wilshanetsky

Exception Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard 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. Routine: The activity must be performed as part of a regular and prescribed course of procedure and be performed in accordance with established practices. B. Repetitive: The activity must be repeated regularly as part of the production process or cycle. C. Integral: The activity must be inherent to the production process.

Minor Servicing Definitions
Routine Part of a regular and prescribed course of procedure and be performed in accordance with established practices (i.e. SOP) Repetitive: Repeated regularly as part of the production process or cycle (See ISO for definition of “frequent”) Integral Inherent to the production process Refer Students to the MIOSHA Document.

Maintenance or Servicing
Constructing Equipment Electrical work Changing tooling Set up Clearing jammed materials Cleaning Removing equipment Modifying equipment Lubrication Repairing Equipment Installing Equipment

Servicing and/or maintenance during normal production operations are covered if: Remove or bypass a guard or other safety device Required to place any part of his or her body into the point of operation or an associated danger zone exists during a machine operating cycle. These are point that go beyond the “minor” servicing exemption

Define: LOCKOUT The process of blocking the flow of energy from a source to a piece of equipment and keeping it blocked. Lockout is not opening an interlock Lockout is not just shutting the machine down Key point = must block the flow of energy and keep it blocked Photo courtesy of BWC employee Roman Wilshanetsky Photo courtesy of BWC employee Roman Wilshanetsky

Define: TAGOUT A warning not to restore energy. It is not a physical restraint but has the same effect as a lock. Tags should be standardized throughout the facility. A tag by itself should have a pull strength of 50 lbs. Resist deterioration from weather or chemical exposure Key = Tag is a warning device Can’t use tagout if Lockout is feasible Should be used very rarely Photo courtesy of BWC employee Debra Higginson

Define: AUTHORIZED A person who locks and tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. Who are these people in your company? Examples: Maintenance, set-up personnel, supervisors, operators, qualified confined space entrants, housekeeping personnel Scenario: Housekeeping personnel is changing a light bulb, does LOTO apply? No, this would fall under electrical standards. However, if the light bulb to be changed was inside the guarding for a piece of equipment, then LO would apply. Photo courtesy of BWC employee Roman Wilshanetsky

Responsibilities of Authorized
Have sufficient number of locks with lock identification, tags and keys to fully isolate all energy sources during maintenance or service of a machine or equipment. Properly apply these energy isolating devices, lock(s) and tag(s). Assure that all key(s) related to LOTO are properly controlled so that the locks cannot be removed without your knowledge. Understand and follow the procedures of the LOTO program. Be responsible for following LOTO procedures that have been developed for specific equipment or machinery maintenance operations in your workspace. These are good statements to include in written program. Job description for Authorized employees

Define: AFFECTED A person who normally operates machines or equipment which will be locked and tagged out during service or maintenance. Affected employees are not responsible to perform the Lockout/tagout. Who are these in your company? Examples: Operators, quality inspectors, housekeeping When does Affected become Authorized?

Define: OTHER Any other person who must be able to recognize when machines or equipment have been locked or tagged out for service or maintenance. Who are these people? Everyone else including office staff, visitors, customers, outside custodial staff

Responsibilities of Affected and Other
Understand the purpose and importance of the LOTO program. Recognize when the LOTO procedure is being implemented in your facility. Make certain not to attempt startup and use of equipment that has been locked or tagged out. SIMPLY: Whenever there is a LOTO device in place on an energy isolating device, leave it alone and do not attempt to operate the equipment. Again, good statement to include in written program Job description for Affected and Other

Other Definitions Energy Isolating Device--Mechanical device that physically prevents the transmission or release of energy (disconnect switch, line valve, manually operated circuit breaker) Control circuitry type devices are not energy isolating devices (push buttons, selector switches, interlocks) Lockout Device--Device that utilizes a positive means to hold an energy isolating device in a safe position and prevent energization Push buttons, selector switches and other control circuit type devices are not energy isolating devices because they are electronically controlled and can fail. This is why interlocks cannot be used as lockout. Lockout device – means to hold isolating device in “off position”. It is the actual lock (standard lock or combination lock)

Two Types of Energy Kinetic
Energy in motion even after power supply is off (fly wheel) Potential Stored force in an object even when the object is not in motion (compressed gas, stretched spring) Two types of energy that must be considered when identifying sources are Kinetic and Potential Kinetic – energy in motion such as a flywheel on a press Potential – think about what stored energy may be part of the machine. Examples include ball valve bumped open when thought it was turned off. Check valves inside the equipment on piping and air tanks Class Activity: Have class write down all the energy sources they can think of (2 min)

Identify Sources of Energy
Electrical Hydraulic Pneumatic Thermal Water Reactive Steam Mechanical Cord & Plug equipment Flammable Gravity Chemical Acid Corrosive

Energy Control Program (c)(1)
Establish a program consisting of: Energy control procedures Employee Training Periodic Inspections Ensure that before equipment maintenance is performed, the equipment’s energy sources are isolated and rendered inoperative. Develop an “umbrella program” to address all the main points of the lockout program. Purpose: Ensure before equipment maintenance is performed, the energy sources are isolated and rendered inoperative.

Lockout/Tagout (c)(2) Employers shall utilize lockout, unless the employer can demonstrate the utilization of a tag-out system will provide full employee protection. Whenever equipment is modified, replaced or renovated, they shall be made capable to accept a lockout device. Discuss the differences between Lockout and tagout Significant updates to equipment shall be modified to be locked out Photo courtesy of BWC employee Roman Wilshanetsky

Full Employee Protection (c)(3)
Use of a tag-out device on a lockable energy isolating device: Tag-out device attached at the same location as the lockout device Employer shall demonstrate that the tag-out program will provide a level of safety equivalent to that obtained by using a lockout program. Use of tags in lieu of lockout – must provide equivalent to the level of safety obtained by using a lockout program Some Negatives to tagout System Must be used in Same Location as the lockout Additional Safety Measures must be used along with the tag (remove circuit breaker or a valve handle Must provide the same level of protection Addition training requirements for a tagout System During the Periodic Inspection process must include Affected along with Authorized Employees

Procedures for Each Piece of Equipment (c)(4)
Procedures shall be developed, documented and utilized for the control of potentially hazardous energy for each piece of equipment. If machinery or pieces of equipment are similar, just one procedure will cover all like pieces. Company must have written procedures describing how to control the hazardous energy sources for each piece of equipment. Like pieces of equipment can utilize the same procedure Like equipment utilizes the same energy sources Don’t have to have switches in the same location Don’t have to be the same manufacturer If you do this, then label the energy sources on the equipment and note this in the procedure. A = Air and is located…. CPL pg Procedure Grouping Equipment may be grouped together as one procedure if they all are listed or identified in the scope of the energy control procedures and if they all have the same or similar: Procedural steps for shutting down, isolating, blocking, securing, and dissipating stored energy; and B. Procedural steps for the placement, removal and transfer of lockout devices and the responsibility for them; and C. Requirements for testing equipment to determine and verify the effectiveness of LOTO devices and other control measures

Energy Control Procedure “Exception” (c)(4)(i)
The employer need not document the required procedure for a particular machine or equipment, when all eight elements exist. Not a recommended practice. To determine if a piece of equipment meets all eight may be more difficult (and take more time) than to write a procedure. Not a recommended practice. If you want to know the exceptions, check the standard.

Eight Elements The machine: Has no potential for stored energy
Has a single energy source The energy source will completely de-energize and deactivate Isolated from that energy source and locked out during servicing or maintenance

Eight Elements (continued)
A single lock-out device will achieve a locked- out condition Lockout device is under the exclusive control of the authorized employee Servicing or maintenance does not create hazards The employer, in utilizing this exception, has had no accidents involving an unexpected activation or re-energization

Energy Control Procedure (c)(4)
Procedures shall clearly and specifically outline: Scope Purpose Authorization Rules Techniques for the control of hazardous energy Enforcement Elements in your “umbrella procedure” Example in your book TAB 4

Energy Control Procedure (c)(4)
The means to enforce compliance include: Specific statement of intended use Specific steps for shutting down, isolating, blocking and securing equipment Steps for the placement, removal and transfer of devices and the responsibility for them Requirements for testing equipment to determine and verify the effectiveness of lockout/tagout devices One statement in your written program that you will follow your progressive discipline policy. Keep a folder of all safety related disciplines to be used for OSHA reviews.

Energy Source Identification
Lockout/ tagout Energy Source Identification Machine: Compressor Date: 12/10/2010 Location: Auto Shop Department: Maintenance Person Identifying Sources: John Doe, Maintenance supervisor Type of Energy YES NO Method, Device or System Selected to De-energize. Quantity of Energy Source (i.e. Voltage, Velocity, PSI, etc. Electrical X Close disconnect on wall behind unit & lockout. Check with tester Volts. Hydraulic Close valve on left end. Open pressure release valve below it. Allow pressure to escape (15 minutes) PSI Lockout Pneumatic Shut valve on right end and open bleeder valve, lockout, wait 15 minutes for pressure to bleed down PSI Chemical Thermal Mechanical Cord & Plug Connected Engulfment Hazard Other Example of documenting the energy sources for a specific type of equipment Include magnitude of the energy source – something authorized employees must be trained in. Tab 4, pg 12 is another example

Protective Materials & Hardware (c)(5)
The employer shall provide locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware Lockout/tagout devices shall be: Devices CANNOT be used for: Lock on a personal locker or tool box Lock “out of service” pieces of equipment B/C it DILUTES the LO/TO program importance. Identifiable Durable The only device used for controlling energy Not be used for other purposes Standardized Substantial Photo courtesy of BWC employee Roman Wilshanetsky Photo courtesy of BWC employee Roman Wilshanetsky

Durable Capable of withstanding the environment for the maximum period of time Tagout devices constructed and printed to withstand wet/damp locations Tags shall not deteriorate when used in corrosive environments (acid and alkali chemicals) Standardized Lockout/tagout devices shall be standardized by: a) Color b) Shape c) Size d) Print and format (Tagout devices) Withstand the - environment - wet/damp locations - corrosive environment Saw brass locks at the OSC Standardized – Read Slide

Substantial Lockout devices - prevent removal without use of excessive force (bolt cutters) tagout devices - prevent inadvertent or accidental removal. Identifiable Lockout/tagout devices indicate the identify of the employee applying the device(s). READ SLIDE Photo courtesy of BWC employee Roman Wilshanetsky

Photo courtesy of BWC employee Roman Wilshanetsky Photo courtesy of BWC employee Roman Wilshanetsky Photo courtesy of BWC employee Roman Wilshanetsky SHOW THE HARDWARE Photo courtesy of BWC employee Roman Wilshanetsky Photo courtesy of BWC employee Mark Walsh Photo courtesy of BWC employee Roman Wilshanetsky

Periodic Inspection of your Procedures (c)(6)
Certification to include: Date of inspection. Machine or process to review identified. Names of persons involved in LO/TO. Name of person doing inspection. Copy of inspection kept on record. Evaluation is on the Procedure, not the employees. Want employees to be comfortable with the inspection and be willing to talk about the effectiveness of the procedure. Not a time for disciplinary action. 14

Periodic Inspection (c)(6)
Employer shall conduct a periodic inspection of the energy control procedure at least annually The inspection is performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected The inspection shall be conducted to correct any deviations or inadequacies identified Performed by an authorized employee that is not at that instance conducting the lockout. Purpose of the inspection: correct deviations and inadequacies in the program

Periodic Inspection (c)(6)
Inspection shall include a review of the procedure for each authorized employee's responsibilities Tagout inspections shall include both authorized and affected employees Employers shall certify that the periodic inspections have been performed. An employer has 10 unique procedures for 100 pieces of equipment. There are 20 authorized employees who use all 10 procedures and one inspector who visually audits each procedure by watching an authorized person perform the lockout. How do they comply with (c)(6)(i)(C) which states that a review between the inspection and each authorized employee occur? [Margetiak, Joseph S. - OSHA] Each employee does not have to be audited for each procedure but each employee has to have the information so the training is often done in a classroom setting.

Training and Communication (c)(7)
Provide training to ensure that the purpose and functions of the energy control program are understood by employees. Levels of training: Authorized Affected Others Training can be accomplished by using the slides provided in your manual, also available on our website. Videos from our Lending Library are also available and useful. Order online or by phone or form.

Training of Authorized Employees (c)(7)(i)(A)
Recognition Type Magnitude Methods/means for energy isolation and control Magnitude is important to OSHA. Make sure your employees are well informed. This can be done by documenting it on your procedures or using the Energy Source Evaluation Form Tab 4 – pgs 16, 17, 18 List of Authorized Employees or use sign in sheet

Training of Affected/Other Employees
Affected Employees Purpose and use of the energy control procedure. Other Employees The procedure and the prohibition of restarting or re-engineering locked out equipment Training should be completed upon hire Make sure training occurs at orientation training Use a training video and review your program elements, including discipline Show types of locks used in your facility Must know: If they see a LO lock they must stay away from machine

Employee Retraining (c)(7)(iii)
Employee retraining shall be provided for all authorized and affected employees when: A change in their job assignments A change in machines, equipment or processes that present a new hazard A change in the energy control procedures. Recommend doing ANNUAL REFRESHER TRAINING for all employees to help re-enforce the importance of the program

Retraining and Certification
Additional retraining shall also be conducted when a periodic inspection reveals that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures. Employer shall certify that training has been accomplished and is being kept up to date. Certification shall include the employee’s name and dates of training. Periodic Inspections may lead to additional training. OSHA will be looking for a list of Authorized and Affected Employees. There are forms in TAB 4 or just provide your training records. Be sure they are kept up to date.

Energy Isolation (c)(8)
Lockout/ tagout shall be performed only by the authorized employees who are performing the servicing or maintenance. Include statements in your written program and specific procedures Affected Employees CANNOT perform the steps of Lockout. Other Authorized employees CANNOT assist in the services/maintenance unless they too have affixed their lock. Notification is apart of your specific procedures. Photo courtesy of BWC employee Roman Wilshanetsky

Notification of Employees (c)(9)
Affected employees shall be notified by the employer or authorized employee when lockout occurs Notification shall be given before the controls are applied, and after they are removed from the machine or equipment.

Application of Controls (d)
Lockout/ tagout procedures shall cover the following elements which will be done in the following sequence: Preparation for shutdown-authorized employee has knowledge of type and magnitude of the energy, hazards and method to control the energy Equipment shutdown-orderly shutdown GO TO TAB 4 PAGE 4-13 to follow along with an examples of a machine specific procedure. PREP FOR SHUTDOWN = #1 step Equipment Shutdown = Steps 2 & 3 starts with notifying affected employees

Equipment isolation Energy isolating devices to be physically located and operated Lockout/ tagout device application Attached by authorized employees & will hold the energy isolating devices in a "safe" or "off" position. Stored energy Potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe. Equipment Isolation - #4 step LO/TO Application - #5 step Stored Energy - #6 step

Verification of Isolation – Prior to starting work on equipment that has been locked/tagged out, the authorized employee shall verify that isolation and de-energization of the machine or equipment have been accomplished. Lock...Tag...Try...and Test! Verification = #7 Very important step. Make sure your authorized employees know not to skip this step. Lock Tag AND TRY! Photo courtesy of BWC employee Roman Wilshanetsky

Release from Lockout or Tagout (e)(1) & (2)
Before lockout/ tagout devices are removed, the following actions must be taken: Work area inspected for tools, parts, equipment components Work area checked to ensure employees are in a safe location Notify affected employees of removal of LO/TO Don’t forget the removal process of the procedures. Steps 1-3 on sample form

Lockout Device Removal (e)(3)
Each device shall be removed by the employee who applied the device Exception: If authorized employee is not available to remove device then device may be removed under the direction of the employer Employer must provide specific documented procedures and training for device removal (include in written program) Step 4 EXCEPTION IN THE STANDARD must have documented procedures might state that locks will be cut Can use a Master Key (based on an interpretation letter) but must have very detailed procedures on how to use State this in your UMBRELLA PROCEDURE

Lockout Device Removal (e)(3)
Procedure shall include 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 Ensuring that the authorized employee knows that the device was removed before resuming work at that facility This should be in the UMBRELLA procedure

Testing/Positioning of Equipment (f)(1)
Testing or positioning of equipment when devices must be removed-the following sequence of actions shall be followed: Clear the equipment of tools and materials Remove employees from the equipment Remove the lockout/tagout devices Energize and proceed with testing/positioning De-energize and reapply energy control measures Part of the UMBRELLA PROCEDURE If this applies, add to your training of the Authorized Employees

Procedures on How You Will Communicate with Contractors on LO/TO.
Who What When Where How 11

Outside Personnel (f)(2)
Contractors, outside service personnel, etc. The on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures. The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer's energy control program. Have a documented conversation between you and the contractors. Review each program and decide together which shall be followed. Ensure your employees are aware the of the contractor’s program and that they are required to follow.

Group Lockout/Tagout (f)(3)
Service or maintenance performed by a crew, craft, department or other group, shall utilize a procedure which affords all the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device. Primary Responsibility is vested in an authorized employee When more than one crew, or department is involved, an authorized employee is designated to coordinate affected work forces and ensure protection. When Working In Groups must provide equivalent level of protection for all employees Each authorized employee shall attach his/her lock or use a lock box With more that one crew, there will be a PRIMARY AUTHORIZED PERSON to coordinate all the efforts Photo courtesy of BWC employee Mark Walsh

Lockout/ Tagout Flowchart

Lockout/ Tagout Flowchart Part Two

Elements of a Lockout/Tagout Program 29 CFR

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Elements of a Lockout/Tagout Program 29 CFR

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