So does every single energy isolation REQUIRE a written procedure/plan that identifies the types of energy, their magnitude, the means used to isolate them, and the means used to verify zero energy state (ZES)? YES… there is ONLY ONE (1) special exemption that excuses us from having a task-specific isolation procedure/ plan, and that exemption can be found in 1910.147(c)(4)(i). But before we get too excited about OSHA giving us a loophole to having a WRITTEN ISOLATION PLAN for every LOTO, we need to see the eight (8) criteria that OSHA has set forth for the “exception” to apply, and I do think many will be sorely disappointed…
This exception says the following… (and please keep in mind that ALL eight (8) conditions have to be met to use this exemption)
(emphasis added by me)
The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist:
(1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees;
(2) the machine or equipment has a single energy source which can be readily identified and isolated;
(3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment;
(4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance;
(5) a single lockout device will achieve a locked-out condition;
(6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
(7) the servicing or maintenance does not create hazards for other employees; and
(8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.
So if we have a “simple lockout” (my term, not OSHA’s) where we have a single energy source that can be locked out using a single isolation device and a single LOTO lock, and this lockout requires NO OTHER actions to prevent the re-accumulation of stored energy, then we have a situation that may not require us to have a DOCUMENTED/WRITTEN ISOLATION PLAN. But folks, these LOTOs are the simplest of all LOTOs, and unfortunately, in many facilities, LOTO is never this easy. But I know there are occasions where we need to merely turn off one electrical disconnect to achieve a ZES condition and that all the other requirements for the exception apply, and thus, there are times the exception is VALID.
But those times/occasions are rare in processing facilities compared to a “normal LOTO,” which leads me to my point…
When performing energy isolation on a job that is rarely done (e.g., a line break to replace a 20-year-old valve), we MUST HAVE a WRITTEN ENERGY ISOLATION PLAN associated with this task/activity. Merely having a work permit that requires a box to be checked next to the statement “All energy sources are isolated” is NOT, even in our wildest dreams, an energy isolation plan!
(See OSHA’s Case Study 5: Sour Water Pipeline Repairs).
Our isolation plan MUST identify the VERY SAME items that our “machine-specific procedures” must identify! We get NO exceptions to what our “complex isolation” procedure must contain as compared to the simple machine-specific procedure. These items are:
- Type(s) of Energy Source(s)
- The magnitude of those Energy Source(s)
- Means used to Isolate those Energy sources
- Means used to Verify EACH Energy Source is at ZES
- OPTIONAL… location of the energy isolation devices
The optional item comes in handy when doing large complex LOTOs using the Group Lockout Method(s), as the person who applied the locks at the start of the work may not be the same person tasked with returning the equipment to service after the work is done. On multiple occasions, I have seen multiple people spend hours looking for a locked-out valve merely because the person who did the LOTO was not available to tell them which “valve” he used or which “breaker” he used. But “Location” is OPTIONAL.
If we are using a safe work permit to authorize the work, either the actual permit must document the energy isolation plan, or we attach an isolation plan worksheet to the permit. But our work permits/documents MUST contain the items listed above so that ANY qualified operator could pick up and “walk it down” without problems.
So bottom line… safe work permits that merely have a “check-the-box” line item regarding the energy isolation for the task/activities is NOT compliant with the most basic LOTO requirement – SPECIFIC procedures 1910.147(c)(4)(ii). Many permits do not have the space to be able to document a complex energy isolation plan, so most processing facilities use an energy isolation plan worksheet and attach it to the work permit. This worksheet is an OFFICIAL part of the work permitting process and falls within the facility’s record retention and disciplinary policies.