It is the year 2018 – OSHA promulgated its Control of Hazardous Energy standard (1910.147) in 1989. That means we should have been practicing LOTO for nearly 29 years, and yet we continue to see unreal failures related to workers performing servicing and maintenance without “locking it out.” This week’s Incident Alerts contained an incident…...
LOTO failure of enormous proportions! Read More »
This report presents the results of the Occupational Safety and Health Administration’s (OSHA’s) “Lookback” review of the Agency’s Control of Hazardous Energy Sources standard, also known as the Lockout/Tagout standard. The standard, which is codified in OSHA’s general industry standards at 29 CFR 1910.14 7, establishes requirements employers must follow to disable machinery and equipment…...
Results of OSHA’s look back review of the LOTO standard docket S-012-B Read More »
OSHA’s Lockout/Tagout (LOTO) standard is pretty clear… ALL servicing and maintenance activities that require the control of hazardous energy require a machine/equipment SPECIFIC written procedure. (e.g. 1910.147(c)(4) 1910.147(c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. So does…...
Using the “energy isolation plan” worksheet to meet specific LOTO procedures Read More »
To continue with my series of LOTO articles this month, I want to discuss how 1910.147 plays into our efforts to enter a Permit-Required Confined Space (PRCS). Way too many PRCS entry permits have the basic check-the-box statement “All energy sources isolated – YES/NO”. What the heck is that suppose to meet? Do our “machine…...
Documenting the “isolation” of a Permit-Required Confined Space Read More »
As the debate continues about using “clamshells” as a lockout device, our behind-the-scenes discussions continue regarding OSHA’s use of the term “Substantial”. The discussion was so good I asked if I could summarize and post it to keep the discussions going. So once again, here is OSHA’s definition of a “Lockout device”: A device that…...
Is a “Lockout device” more than a Lockout Lock? Read More »
Way back in April 2016, the OSHRC published a decision that settled the argument about LOTO procedures for “specific equipment/machines” and what they must contain. This important decision helped settle a lot of scuttlebutt about how LOTO gets managed in “complex” situations. I like to explain to clients that LOTO in a chemical process is…...
Chemical Processes, LOTO, and three (3) program buckets (Simple, Traditional, Complex) Read More »
To follow up on the post from yesterday regarding the use of these “lockout devices”, I was reminded by many of you in the same camp as me, that these devices are also highly questionable when we look at their ability to meet the “substantial“ requirement. These safety pros all agreed that the use of…...
LOTO, “Clam Shells”, OSHA, and “substantial” Read More »
UPFRONT DISCLAIMER: I am not suggesting you throw out any of your LOTO devices or change your practices. This is NOT advice, merely an attempt to demonstrate how some companies go above and beyond OSHA minimums. In my days working in the chemical industries, I had the pleasure of working with some of the finest plant managers,…...
Do “clam shells” comply with OSHA’s definition of “Lockout Device” Read More »
The state of NC has its own OSHA Plan (e.g., State Plan), but they use the Federal OSHA standards as their enforcement tools. As like most state plans, their website is a buffet of safety materials that are free for the taking. In fact, I used some of their materials when I was a safety manager in…...
NC-OSHA’s acceptable “Lockout Lock” identification method… would you accept this? Read More »
A 51-year-old female employee was fatally injured when she leaned into a machine and was pinned, resulting in crushing injuries to her head and neck. On the day of the incident, the victim was helping out on windshield #1 line due to low staffing levels resulting from inclement weather. She was to keep the line running and relieve…...
LOTO Fatality (TN-OSHA) Read More »
The standard specifies several information collection requirements. The following sections describe who uses the information collected under each requirement and how they use it. These requirements aim to control the release of hazardous energy while workers service, maintain, or repair machines or equipment when activation, startup, or release of energy from an energy source is…...
What is OSHA’s LOTO documentation requirements? Read More »
The US Chemical Safety Board’s (CSB) most recent Safety Bulletin: Key Lessons from the ExxonMobil Baton Rouge Refinery Isobutane Release and Fire was once again a great piece of work by the agency. But as with most incidents, other underlying issues may have contributed (or not) to the incident. In this bulletin, I could not help but notice…...
Did you see the “tagout” in CSB’s latest Bulletin Read More »
