I spent this week surrounded by safety pros who wanted to learn the finer details of safety; one day was dedicated to LOTO. I always get some questions about spending a day on LOTO… “what the heck are we going to talk about LOTO for 8 hours?”. I think that if you were to poll the class from this week they could answer that question! Having been a busy week, I have been amiss in my participation in my social media groups, but one of the students this week felt the need to show me the following picture, which is just UNEXCUSABLE in 2017…
To make matters even worse, this is the statement made by the poster:
“It’s that time of the year again. Beautiful morning for strainer cleaning. Don’t mind what the tag out says. I just ran out of color flags.”
Some background:
This job involved a “process opening,” as can be seen in the photo. The material in this process is Anhydrous Ammonia (NH3). This worker used “tagout” rather than a lockout. Take a good look at the photo and name three (3) mistakes that make this energy isolation pathetic:
What would OSHA say about this LOTO?
Issue #1
1910.147(c)(2)(ii) If an energy isolating device is capable of being locked out, the employer’s energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section.
All of these valves are “lockable” and should have been “locked out” rather than “tagged out”. But since they were “tagged out” (rather than “locked out”), the facility should have abided by the “Tag-Plus” requirement to demonstrate FULL EMPLOYEE PROTECTION…
1910.147(c)(3)(i) When a tagout device is used on an energy isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.
1910.147(c)(3)(ii) In demonstrating that a level of safety is achieved in the tagout program which is equivalent to the level of safety obtained by using a lockout program, the employer shall demonstrate full compliance with all tagout-related provisions of this standard together with such additional elements as are necessary to provide the equivalent safety available from the use of a lockout device. Additional means to be considered as part of the demonstration of full employee protection shall include the implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.
I will say this; the facility may have additional valves “tagged out” that are not shown in this picture.
Issue #2
Did you see anything else that is problematic with this setup?
I will use a phrase that a good friend and colleague reminded me of this week as a hint… “words mean something.” Look at the wording on the tags? “DO NOT CLOSE VALVES”… now can we see the problem?
Issue #3
1910.147(c)(5)(ii)(C)(2) Tagout devices. Tagout devices, including their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal. Tagout device attachment means shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and having the general design and basic characteristics of being at least equivalent to a one-piece, all environment-tolerant nylon cable tie.
As can be seen in the photo, the tags and their application are not:
- substantial enough to prevent inadvertent or accidental removal
- non-reusable type
- self-locking
- non-releasable with a minimum unlocking strength of no less than 50 pounds
Issue #4
1910.147(c)(5)(ii)(D) Identifiable. Lockout devices and tagout devices shall indicate the identity of the employee applying the device(s).
It could be possible the authorized employee wrote his/her name down on the back of the tag(s); but it is clear they did not place their name in the section of the tag(s) where it is intended to be placed.
I think we can agree that this posting is more of “how NOT to do an energy isolation.” The fact that an individual is comfortable enough to post this in a social media discussion forum dedicated to his “trade” in 2017 is shocking… what’s even more shocking is that his post is just three (3) days old. He has collected 71 “likes,” 1 “heart,” and 2 “wows.” And I’d like to add that the two (2) “wows” are from personnel who appear to be OUTSIDE of our U.S.A. OSHA enforcement!!!! When one of the “techs” in the group pointed out that he/she used the wrong tags, the worker replied:
“good catch. I ran out of tags just used something to remind me to put it back to normal operation.”
Folks, it is 2017, darn near 2018; OSHA’s LOTO standard 1910.147 has been around for nearly 30 years, and this is how we performed energy control in 2017. And an energy control on a process with Anhydrous Ammonia! We must do better when the stakes are this high; not meeting the OSHA minimums invites trouble.