This OSHA citation involves items other than LOTO. Still, the LOTO citations caught my eye precisely because the equipment-specific procedures did NOT state how pneumatic sources (e.g., air) were to be verified at a Zero Energy State (ZES). The means to verify a ZES is a critical step in LOTO, and far too often, the procedure will merely state… “Verify Zero Energy” does not tell the user HOW TO VERIFY a ZES for each energy source. This OSHA citation points out the following:
- Procedures do not indicate the location of the air valves, how to lock them out, and how to verify that they have been de-energized.
- Procedures do not indicate the location of the main power or how many electrical boxes are needed to be locked out
- Verification step of the LOTO procedure for pneumatic does not specify how to verify that the pneumatic energies were locked out
- Specific written procedures did not include the magnitude of energies, location of energy sources, and verification of de-energized energy sources
Just like we tell authorized employees to use the “Start/Stop Button” to verify the electrical energy is at a ZES, we have to provide the means to verify that the air is at a ZES. Pneumatic sources are “stored energy” and require EXTRA steps to bleed off the energy AND to ensure the energy does not re-accumulate due to a leaking isolation device. This is why I always suggest the use of a “dump valve” for pneumatic sources.
