I don’t think many safety pros would argue with this statement: LOTO requires that all forms of hazardous energy be taken to a ZES before servicing and maintenance begin.
But I have had many discussions about DEFINING and QUANTIFYING what a “hazardous form of energy” is. Since OSHA has not quantified the term “hazardous energy”, many written LOTO programs and training programs do NOT define and quantify which energy sources require LOTO. Yes, we can say ALL energy sources must be taken to their ZES, and we would be covered, but is this reality?
It is clear that all forms of “hazardous energy” must be taken to their ZES, but how we DEFINE and QUANTIFY what a “hazardous energy” source is MATTERS IMMENSELY to the proper scope and application of our program. Here is how OSHA trains their CSHOs to define “hazardous energy”:
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Hazardous Energy. Any energy, including mechanical (e.g., power transmission apparatus, counterbalances, springs, pressure, gravity), pneumatic, hydraulic, electrical, chemical, nuclear, and thermal (e.g., high or low temperature) energies, that could cause injury to employees. Danger is only present when energy may be released in quantities or at rates that could injure employees. NOTE: Thermal energy may be generated as a result of electrical resistance, mechanical work, radiation, or chemical reaction, such as is the case with anhydrous ammonia, chlorine, or sulfuric acid reacting with skin, lung, or eye tissue causing chemical burns. Hazardous chemical energy, for purposes of this standard, includes chemicals (e.g., flammable and combustible liquids; flammable gases; acids and alkaline chemicals) that may thermally produce burn injury through high or low temperature. |
In 2018, I wrote about a situation I ran into in the 1990s that taught me a valuable lesson regarding the scope and application of LOTO. It involved changing out a water fountain filter, and the mechanic followed the program and the training to the letter. This was a “closed system” that had “energy” that needed to be isolated for him to get a line/break permit. I can’t argue with his actions because that is precisely what our program and training required.
So, does our LOTO program DEFINE and QUANTIFY which energy sources are “hazardous”? In this post, I will use the two most common forms of energy found in every workplace:
- Water
- Compressed Air