I like direct statements and clear concise rules when it comes to drawing the lines of safety and production and maintenance. But too often, these lines get drawn in the wrong spot and cause safety all kinds of issues and let’s admit it… gives safety a bad name. One such line is when lockoout/tagout (LOTO) applies. We can not just state that LOTO applies for all “servicing and/or maintenance” tasks as OSHA defines these tasks:
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.
I have actually re-engineered some equipment for the sole purpose of allowing workers to perform certain “servicing and/or maintenance” tasks WITHOUT having to apply LOTO to do the work safely. In fact, in some facilities, by making these changes we kept several hundred workers as “affected workers” ALL THE WHILE making their work SAFER! Here is one such real world example of what we did:
We had a unit that had an area we called “pump alley”, which consisted of nearly 100 pumps. These pumps were in our Preventive Maintenance (PM) program due to the materials they were pumping were “hazardous materials” and any leak posed a “hazard” to those in the area. Traditional mainteance practices included checking in with the operator(s) and getting them to shutdown the pump, if necessary for the scope of work – prepare the pump by flushing/purging, and isolate the enegy sources associated with the pump. This was done without question and by the letter every single day! One such task that was very routine, sometimes weekly, was merely lubricating the pump. Almost all of the pumps were the same brand and model and the grease connection was down at the base of the pump. In order to connect the grease gun to the fitting, a guard had to be removed – this of course meant the pump had to be LOCKED OUT for this greasing task that was a daily activity.
Doing these LOTO’s each day on varying pumps had become a way of life for the operators in this unit. In fact, it was these pumps where rookie operators learned LOTO and demonstrated their ability to perform an energy isoaltion on a “pump”. In my entire time at this facility (4 years) no one questioned the frequency or the loss of the pumps use. The came along Six Sigma and KPIs and then somone came to the safety group and asked…
Is there any way we could lessen the down time of these 100 pumps?
This “down time” was 98% due to the PM’s, with the most frequent PM being the greasing task. No one was asking to do away with the PM’s or to chnage the frequency of the PM(s), but was there a way we could shorten the time it took to do the PM task? When we got to the PM that was most frequent – Greasing, one of the maintenance mechanics wondered if we could just extend the grease gun connection outside of the guard so that he/she could simple walk up to a pump that is running and connect his/her grease gun to the fitting(s) and grease the pump while it is running and GUARD(S) ARE IN PLACE. At no time will the worker need to OPEN/REMOVE/BYPASS any gaurd or safety device to perform this “servicing and/or maintenance” task – hence we can SAFELY do our “servicing and/or maintenance” task(s) using MACHINE GAURDING in lieu of LOTO. OSHA makes this clear in their LOTO CPL (2008) when they state:
The LOTO standard does not apply if employee exposure to hazardous energy is eliminated through compliance with the Subpart O, machine guarding, requirements.
OSHA’s LOTO CPL lists some more example of the relationship or complementary nature of these LOTO and machine guarding standards.