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. III. IV. Trends & Interpretations I. OSHA Instruction Directive II. Frequency of Incidents & Citations Your Feedback Alternative Protective Measures V. Effective Energy Control Programs
About Brady 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.
Why Lockout / Tagout? 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? 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 accidents More than 700 fatal events Causes of these events include: Failure to stop equipment Failure to disconnect from power source Failure to dissipate (bleed, neutralize) residual energy Restarting 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 energy De-energize circuits Block moving parts Release pressure Neutralize extreme temps Prevent chemical exposure
Key Standards & Regulations OSHA OSHA 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. CSA CAN/CSA-Z460-05 Control of hazardous energy Lockout and other methods ANSI ANSI/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
Recent OSHA Instruction Directive - Key Points OSHA Compliance and Safety Officers will evaluate the effectiveness of the employer s training program by verifying that: Authorized employees recognize and understand All applicable hazardous energy sources Type and magnitude of energy Means and methods of isolating and/or controlling energy Means 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 procedures All other employees who work in the area are instructed
Recent OSHA Instruction Directive Key Points LO/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
Lockout / Tagout Facts 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! So what are the top 5 violations?
Lockout / Tagout Facts Top 5 OSHA LO/TO violations: 1) Failure to establish and implement a written lockout PROGRAM 2) Failure to develop, document and utilize MACHINE-SPECIFIC PROCEDURES 3) 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 Machine-Specific Procedures Employee Training
LO/TO: A Lot More Than Just Devices! 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
Step 1: Create Energy Control Policy & Procedures Per OSHA: LOTO Policy Must Include*: Purpose and scope Personnel authorized Enforcement policy Training methods Group lockout procedures Shift transfer procedures Lock removal procedures Method for auditing procedures Coordination of outside contractors
Step 1: Create Energy Control Policy & Procedures Also Per OSHA: LOTO Procedures: Must be documented and identify the equipment covered A separate procedure must be created for each distinct piece of equipment to be locked out The procedure must include specific steps for shutting down, isolating, blocking and securing equipment to control hazardous energy Includes specific steps for the placement, removal and transfer of LO/TO devices Employer shall conduct and certify periodic inspections at least yearly
Step 2: Identify All Energy Control Points 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 3: Provide the Proper Lockout Tools & Warning Devices OSHA Lockout Device Requirements: Lockout Devices must in-part be: Provided by the employer Standardized by size, shape or color Distinguishable 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 environment Strong enough to prevent removal except by excessive force Remain under exclusive control of the individual who attached
Step 3: Proper LOTO Tools & Devices KEY REQUIREMENTS: Durability Security / safety Easy to use Easy storage / portability Versatility Lower equipment costs Simplified training Less chance for mistakes
Step 3: Proper Tools Offering
Step 3: Cable Lockouts All Purpose Cable Lockout Mini Cable Lockout Comes with sheathed steel or nonconductive nylon cable.
Step 3: Ball & Butterfly Valve Lockouts Ball valves Butterfly valves
Step 3: Circuit Breaker Lockouts
Step 3: Safety Lockout Padlocks Different than security locks Compact & lightweight Key retaining Exclusive keyways Also look for: Ruggedness & durability Enhanced shock protection Superior rust resistance
Step 3: Identify the Individual Locking Out Tags Must meet OSHA 50-lb. pull test for use as tagout devices Encapsulated or polyester (w/ metal grommet) Not cardstock Labels or permanent markings on locks
Step 3: Proper Tools Group Lockout Scenario: 6 workers (authorized employees) lock out machine having 8 energy isolation points. 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
Step 4: Train Employees & Promote Awareness 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 employees The employer shall certify that the employee training has been accomplished and is being kept up-to-date
Step 4: Training & Awareness Solutions
Resources For more information: OSHA website www.osha.gov/sltc/controlhazardousenergy/index.html Brady website www.bradyid.com/lockouttagout