If you have equipment that uses compressed air (CA) as an energy source, you will understand my frustrations with how poorly we manage this hazardous energy source. Typically, compressed air is provided via a plant-wide header system with drops for machine/equipment. These drops will then use a hose to deliver the compressed air to the […]
LOTO locks can be keyed alike. For example, equipment/field locks can all be keyed to a SINGLE key; however, personal/individual locks MUST BE individually keyed (e.g., 1 key – 1 lock). Before starting work ask yourself this simple but very important question: Do I have EXCLUSIVE/SOLE control of each and every isolation device protecting ME?
One of the more popular findings in our LOTO assessments/audits involves the lack of specific procedures for verifying a zero energy state (ZES) for EACH energy source. The LOTO standard, 1910.147, makes it clear that the energy control procedure must be “specific.”…
The client has approved this posting as they want to make sure others can learn from their incident. PLEASE discuss this incident with your teams if your LOTO practice(s) resemble theirs – what they did was VERY COMMON and I teach this method in all my LOTO courses at process plants. I have revised my
Earlier today I posted a recent OSHA citation where a facility was cited for not having procedures regarding the means to isolate and verify ZES for pneumatic energy sources (i.e. plant air). For some reason, on nearly all of my LOTO projects I find that air sources are a bastardized source of energy when it
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
In 2014, the Occupational Safety and Health Review Commission (OSHRC) issued a judgment on an OSHA case, and in the case, they made it clear that “magnitude” matters in lockout/tagout (LOTO). But for some reason, this piece of data is absent from many machine-specific LOTO procedures and OSHA always takes issue with this oversight. So
We have a machine and this machine has a couple of tasks that have been deemed “minor servicing”. As we walk by we see a worker in the machine and no LOTO in place so of course we stop and ask about the situation. We are told the task being done, “XXXXXXXX”, is indeed a
Under most circumstances, where servicing or maintenance is to be conducted during only one shift by a small number of persons, the installation of each individual’s LOTO device on each energy isolation device would not be a burdensome procedure. However, when complex equipment is being serviced or maintained, when there are many sources of energy,
Anyone who has played sports or even just attended a team sporting event has heard or seen the famous saying: There is no “I” in Team! In our world of Lockout/Tagout (LOTO), nothing could be farther from the truth! There is not an act in occupational safety and health that is more self-serving and selfish
Luckily, these kinds of encounters are dwindling, but even mentioning this in 2019 says a lot for the “State of Safety” in the USA. Have you ever encountered a management group where you hoped Dr. Suess would re-write the OSHA LOTO Std? I mean, they hire us to explain and assist in implementing the basic
Since I shared my article last week on OSHA’s position of NOT allowing “exclusive control” to be carried over to process valves like we do with “cord and plug” electrical equipment, my international friends and clients have been having quite the chuckle at us here in the USA. They all say virtually the same thing…
