Effective Compliance with OSHA’s Lockout / Tagout … What... · Effective Compliance with OSHA’s Lockout / Tagout Standard ... OSHA 29 CFR 1910.147 “Control of hazardous energy

Effective Compliance with OSHA’s Lockout / Tagout Standard

Tom Campbell -Safety & Compliance

Brady Corp.

Agenda

I. OSHA’s Focus on Lockout/Tagout in Process Manufacturing

II. Trends & InterpretationsI. OSHA Instruction DirectiveII. Frequency of Incidents & Citations

III. Your Feedback

IV. Alternative Protective Measures

V. Effective Energy Control Programs

Brady Corporation is an international manufacturer and marketer of products and services that identify and protect premises, products and people. Its products help customers increase safety, security, productivity and performance and include high-performance labels and signs, safety devices, printing systems and software. Founded in 1914, the company has more than 500,000 customers in process and discrete manufacturing, electrical, construction, electronics, telecommunications and a variety of other industries. Fiscal 2010 sales were $1.25B.

About Brady

The #1 most frequently cited OSHA regulation for general industry.

#1 most frequently cited for Pulp & Paper

OSHA is focusing on LO/TO violators:3622 violations in 1977 inspections with penalties of

$4.725M in the 25 Federal Jurisdiction States

OSHA citations run from several thousand to several hundred thousand dollars and beyond!

Why Lockout / Tagout?

Why Lockout / Tagout?

Even more importantly, comprehensive and thoroughly followed Lockout programs:

SAVE LIVES – Up to 50,000 injuries & 120 lives each year

CUT COSTS – Avoiding accidents also avoids lost employee time, insurance costs and legal fees

IMPROVE PRODUCTIVITY – Speeds equipment maintenance, minimizing downtime

Are BEST PRACTICE in industry

Accident Summaries Search on OSHA Webpage*

More than 4000 instances of Lockout accidentsMore than 700 fatal eventsCauses of these events include:

Failure to stop equipmentFailure to disconnect from power sourceFailure to dissipate (bleed, neutralize) residual energyRestarting of equipment (intentional or inadvertent)Failure to clear work areas before starting

* From OSHA outreach webinar

Objective of Lockout / Tagout

Protect workers from injury during the maintenance and servicing of equipment

Isolating hazardous energyDe-energize circuitsBlock moving partsRelease pressureNeutralize extreme tempsPrevent chemical exposure

Key Standards & Regulations

OSHAOSHA 29 CFR 1910.147 “Control of hazardous energy (lockout/tagout)

OSHA 29 CFR 1910 Subpart S “Electrical – selection and use of work practices”

2008 OHSA Directive # CPL 02-00-147: Clarifications & interpretations for OSHA inspectors.

CSACAN/CSA-Z460-05 “Control of hazardous energy – Lockout and other methods

ANSIANSI/ASSE Z244.1 “Control of hazardous energy, lockout/tagout & alternative methods

ANSI/ASSE A10.44 “Control of energy sources (lockout/tagout) for construction & demolition operations

OSHA Compliance and Safety Officers will evaluate theeffectiveness of the employer’s training program byverifying that:

Authorized employees recognize and understandAll applicable hazardous energy sourcesType and magnitude of energy Means and methods of isolating and/or controlling energyMeans of verification of effective energy control and the purpose of the procedure to be used

Affected employees have been instructed in the purpose and use of the energy control proceduresAll other employees who work in the area are instructed

Recent OSHA Instruction Directive - Key Points

Recent OSHA Instruction Directive – Key PointsLO/TO of the POWER Circuit is significantly safer and more reliable than CONTROL circuit protective measures:

CONTROL CIRCUIT measures, safety functions, such as stopping or preventing hazardous energy (motion) can fail due to component failure, program errors, magnetic field interference, electrical surges, improper use or maintenance, etc.

Source: OSHA Instruction Directive #CPL 02-00-147

Your Feedback

Top 3 Pain Points _________, _________, _________

Relative importance of LO/TO

Satisfaction with current state of LO/TO

Uncertainty about when lockout is required:

Importance Of:

Tracking Lockout Status

Employee Training

Writing Procedures

Accessing Records

Top 5 OSHA LO/TO violations:− Surprisingly, the use of the proper tools and devices, including safety padlocks, is

NOT one of the 5 most frequently cited OSHA lockout violations!

Lockout / Tagout Facts

“So what are the top 5 violations?”

Top 5 OSHA LO/TO violations:1) Failure to establish and implement a

written lockout PROGRAM2) Failure to develop, document and utilize

MACHINE-SPECIFIC PROCEDURES3) Failure to conduct a PERIODIC

INSPECTION of the energy control procedure

4) Failure to provide TRAINING as described by OSHA

5) Failure to clearly OUTLINE the SCOPE and rules to be utilized, and the means to ENFORCE compliance

Lockout / Tagout Facts

Machine-Specific Procedures

Employee Training

4-Step Plan for Creating an Effective Lockout Program:

(1) Create energy control policy & procedures

(2) Identify all energy control points

(3) Equip employees with the proper lockout tools and warning devices

(4) Train employees and promote awareness of safe work practices

LO/TO: A Lot More Than Just Devices!

Per OSHA: LOTO Policy Must Include*:Purpose and scopePersonnel authorizedEnforcement policyTraining methodsGroup lockout proceduresShift transfer proceduresLock removal proceduresMethod for auditing proceduresCoordination of outside contractors

Step 1: Create Energy Control Policy & Procedures

Also Per OSHA: LOTO Procedures:

Must be documented and identify the equipment coveredA separate procedure must be created for each distinct piece of equipment to be locked outThe procedure must include specific steps for shutting down, isolating, blocking and securing equipment to control hazardous energyIncludes specific steps for the placement, removal and transfer of LO/TO devices Employer shall conduct and certify periodic inspections at least yearly

Step 1: Create Energy Control Policy & Procedures

Summary of OSHA Requirements:Electrical disconnecting means shall identify the energy magnitude and purpose. Per ANSI, all energy isolating devices should be adequately labeled or marked.

Identification shall include:– Machine, equipment, process supplied– Energy type and magnitude

Step 2: Identify All Energy Control Points

OSHA Lockout Device Requirements:Lockout Devices must in-part be:Provided by the employerStandardized by size, shape or colorDistinguishable from locks used for other purposes. Lockout locks should only be used for lockout.Identify the individual who applied the lock (tags are acceptable)Durable, and capable of withstanding the usage environmentStrong enough to prevent removal except by excessive forceRemain under exclusive control of the individual who attached

Step 3: Provide the Proper Lockout Tools & Warning Devices

Step 3: Proper LOTO Tools & Devices

KEY REQUIREMENTS:DurabilitySecurity / safetyEasy to useEasy storage / portabilityVersatility

Lower equipment costsSimplified trainingLess chance for mistakes

Step 3: Proper Tools Offering

Step 3: Cable Lockouts

All Purpose Cable Lockout

Comes with sheathed steel or nonconductive nylon cable.

Mini Cable Lockout

Step 3: Ball & Butterfly Valve Lockouts

Butterfly valves

Ball valves

Step 3: Circuit Breaker Lockouts

Step 3: Safety Lockout Padlocks

Different than security locksCompact & lightweightKey retainingExclusive keywaysAlso look for:

Ruggedness & durabilityEnhanced shock protection Superior rust resistance

Step 3: Identify the Individual Locking Out

TagsMust meet OSHA 50-lb. pull test for use as tagout devicesEncapsulated or polyester (w/ metal grommet)Not cardstock

Labels or permanent markings on locks

Step 3: Proper Tools … Group Lockout

Using Hasps:One hasp applied to each control point. Each worker puts one padlock on each hasp. 6 workers x 8 control points each = 48

Using Lock Boxes:Supervisor secures one padlock to each control point,

then puts keys in the lock box. Each worker puts one padlock on the lock box. 8 supervisor padlocks + 6 worker locks = 14

Scenario:6 workers (authorized employees) lock out machine having 8 energy isolation points.

OSHA Training and Communication Requirements:The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employeesThe employer shall certify that the employee training has been accomplished and is being kept up-to-date

Step 4: Train Employees & Promote Awareness

Step 4: Training & Awareness Solutions

Resources

For more information:OSHA website

www.osha.gov/SLTC/controlhazardousenergy/index.html

Brady website www.bradyid.com/lockouttagout