It is important to emphasize that the machine guarding requirements of 29 CFR Part 1910, Subpart O standards COMPLEMENT THE REQUIREMENTS for LOTO. In some instances, an employer may avoid the requirements of the LOTO, if they ELIMINATE exposure to servicing and maintenance hazards by using machine guarding techniques compliant with those standards. It is also important to […]
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
WOW… my LOTO ppt for “Affected Personnel” that I posted earlier this week has caused quite the “back and forth” with too many people/sites. I just assumed that we had a basic understanding of “who falls into the “affected” bucket” and “what they must know”. Affected employees do NOT need to attend a 2-hour training
WOW… just WOW! I feel like I am in the twilight zone after reading this decision. I am not a big fan of government shutdowns, but right now, I wish the OSHRC would get shut down. It is rare, but it does happen when I take serious issues with decisions of the OSHRC, and this
In this last part of 2018, I have been on a LOTO crusade; I have been to 12 different facilities since August to help them understand LOTO. Some projects were complete new builds, some were to help with implementing Group LOTO, and a few were to training company safety professionals on the OSHA requirements so
One of my favorite courses to teach is my LOTO Overview course, where I try and convey the OSHA minimum requirements for a functioning Lockout/Tagout (LOTO) program, and each time I do this course I always tell my “water fountain story” from my days at Great Lakes Chemical. My plant manager at GLCC was a
Recent technological advancements that employ computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with OSHA’s existing lock-out/tag-out standard. These computer-based controls have become more prevalent as equipment manufacturers modernize their designs. Additionally, national consensus standards and international standards harmonization govern the design and use of computer-based controls. This approach of
This is a follow-up to a previously posted case. An electrical contractor at a steel mill was in a danger zone when the mill technician began locking out the equipment. The LOTO procedure required some counterweights to be lowered to the ground (i.e., ZES). When the mill technician released the counterweight, an apprentice with the
Recent technological advancements that employ computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with OSHA’s existing lock-out/tag-out standard. These computer-based controls have become more prevalent as equipment manufacturers modernize their designs. Additionally, national consensus standards and international standards harmonization govern the design and use of computer-based controls. This approach of
One of the most abused practices involving LOTO is the “myth” that LOTO does not apply when the “energy source” is “under the control of and within line-of-sight of the person performing the activity.” As OSHA points out in this 2007 LOI, this is not necessarily the case:
OSHA’s standard for the Control of Hazardous Energy allows us three (3) means in which we can identify our Lockout locks: 1910.147(c)(5)(ii)(B) Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format
