Lockout/Tagout (LOTO) STARTS WITH machine gaurding. Yes, MACHINE GAURDING – we can not even begin to speak of LOTO until we first have the forms of hazardous energy properly gaurded for our NORMAL OPERATIONS. Because when the machine/equipment is being used for its inteded purpose(s) (e.g. Normal Operations) we are FIRST REQUIRED to ensure that all forms of “hazardous energy” is gaurded so that the workers can safely interface with the machine/equipment while it NORMALLY OPERATES (i.e. the utilization of a machine or equipment to perform its intended production function).
1910.212(a)(1) Types of guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are-barrier guards, two-hand tripping devices,electronic safety devices, etc.
LOTO comes into play when we need to REMOVE/OPEN/BYPASS these safety features on the machine/equipment in order to perform some type of work. To keep this simple, let’s classify this work as “servicing and/or maintenance” as OSHA defines it.
Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpectedenergization or startup of the equipment or release of hazardous energy.
So as we can see, as well as when reading 1910.147, we really can not discuss LOTO without having first discussed Machine Guarding. LOTO is triggered by the action of either:
- a worker is required to remove or bypass a guard or other safety device; or
- a worker is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle