One of the most common causes of work-related fatalities is contact with machinery and equipment. This often occurs when employees are performing some type of service or maintenance on a machine, such as clearing a jam, and the machine unexpectedly starts, becomes energized, or releases stored energy such as compressed air/gas, or hydraulic pressure.
For this reason, we have 29 CFR 1910.147 “The control of hazardous energy”, more commonly known as “lockout-tagout”.
The lockout-tagout regulation covers employees who perform service and maintenance on machines and equipment during which the accidental or inadvertent start up, energization, or release of stored energy could cause injury to employees. In plain English, your organization is probably covered if you have employees who repair, set up, install, clear jams, clean, inspect, etc. machines, which are capable of causing injury by unexpectedly starting, moving, etc. This might include such simple tasks as changing blades on a table saw, or cleaning out spray guns in a spray booth.
One of the most important requirements of this regulation is the development of formal, written lockout-tagout procedures, which detail the steps that are required to bring a specific machine to a zero-mechanical state, thus rendering it safe to perform service and maintenance.
Because the requirements for developing these procedures are complicated and often misunderstood, coupled with the fact that they might be quite time consuming, employers often fail to implement them, fully and properly. Thus, failing to have the procedures completed, and completed properly, is nearly always one of the most common OSHA violations.
Employers sometimes take shortcuts in their development, such as having one general procedure for several, or even all machines in the facility. Or, writing extremely brief procedures of only a few steps. They might also misinterpret one or more of the several exceptions in the law, and erroneously convince themselves that the procedures are not required. But these short-cutting strategies almost always result in citations.
The first step in complying with this regulation is to develop a strong understanding of it. Review the regulation, and remember that the requirements for the written procedures are found in several different places; most importantly 1910.147(c)(4) and 1910.147 (d). Remember that some OSHA compliance officers enforce these requirements verbatim so attention to detail is important.
Here are a few tips:
- Form a committee of safety staff, electrical/maintenance staff, machine operators, etc. This will be too big a job for one person in most cases. Train them on the regulation, and make sure they understand that the devil is in the details of the regulation.
- Set firm but attainable goals for the completion of the procedures. Maybe 5 procedures completed in the first week, 10 in the second week, etc.
- Develop a standard, template form for the procedures. Remember, Minnesota OSHA, and other jurisdictions sometimes enforce the requirements about content of the procedures verbatim, so be sure your template form meets all the requirements. There are some very specific requirements for wording and other content. Better yet, use the template form provided in the appendix of the regulation, and customize it to each machine as needed.
- Be sure you’re clear on what an “energy source” is. The lockout-tagout regulation is all about energy. More specifically how to control it. It apples to all forms of hazardous energy, including electrical, tension, springs, heat, chemical energy, compressed air, hydraulics, etc. Your procedures will need to account for all forms of hazardous energy and how to control them, including some you might not normally consider. For instance, when changing the blade on a radial arm saw, there is often a “spin down” period where the blade coasts to a stop. This is known as “kinetic” energy and must be accounted for in the procedure. Perhaps there are hot parts that need to cool off before work can begin. Again, this must be accounted for. Often, employers scoff and ask if the procedure really must say “wait 15 minutes for part xyz to cool off” or “wait 3 minutes for blade to come to a stop”. My answer is a simple “yes”.
- Survey the entire operation, and identify the machines and equipment upon which your employees or contractors would perform service and maintenance. As you might imagine, it will be a lengthy list.
- For each of those machines, identify whether or not one of the many exceptions in the regulation might apply. For instance, cord and plug connected equipment, such as hand tools, are often exempt. So are machines/equipment which have only one source of energy that can be readily identified and isolated using a single lock. Please note; these are only brief summaries of these exceptions. They aren’t quite as simple as I have made them here.
- Avoid being overly general. The intent of the rule is to provide specific information about a machine. I use the “man on the street” rule. In other words, the procedure needs to be so specific that I can hand it to a man I meet on the street outside the facility, and he should be able to properly perform the lockout. General lockout-tagout procedures do NOT meet the requirements.
- Avoid being too brief. In my audits, I will often find procedures that read like this’ “Step 1. Turn off machine. Step 2. Lock out power”. The end. If you read between the lines of the regulation, you will find that procedures must have at least seven steps. If your procedures have less than seven distinct steps, they do not meet the requirements of the regulation.
- Use photographs to illustrate the various switches, disconnecting means, etc. mentioned in the procedure.
Remember, having the procedures completed isn’t a final step. It’s the initial step. Once completed, there are requirements for training, retraining, and annual inspections of the procedures, which I won’t get into now.