Lockout Tagout

COLOR is NOT the only prescribed factor for the standardization of lockout and tagout (LOTO) devices

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…...

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Contractors and Lockout/Tagout

Those of us under Federal OSHA can let our contractors follow their own LOTO program/practices AS LONG AS they explain them to us.  However, in some states, their OSHA plan requires contractors to support the “on-site employer’s” LOTO program.  As I have written about, most workplaces struggle to manage their contractors PROPERLY when LOTO is…...

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Are you ready for a new LOTO standard, one that would allow interlocks to be used in lieu of LOTO?

If you are a LOTO fanatic, you most likely have heard the “rumor” that OSHA is considering some significant changes to the application of LOTO.  These changes center around using “interlocks” in lieu of locking out the machine/equipment.  In essence, there are some who are “lobbying” OSHA to allow interlocks to be used in situations…...

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Conveyor Accident w/ Pics (LOTO Story)

On May 25, 2016, I was sitting on and repairing an industrial conveyor belt. Suddenly, the conveyor belt started up, and I went on a ride that changed my life forever. I spent 16 days in the hospital, where doctors focused on placing a rod and screws into my left arm (the rod and screws…...

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LOTO failure of enormous proportions!

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…...

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Results of OSHA’s look back review of the LOTO standard docket S-012-B

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…...

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Using the “energy isolation plan” worksheet to meet specific LOTO procedures

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 this…...

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Documenting the “isolation” of a Permit-Required Confined Space

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 supposed to meet?  Do our “machine…...

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Is a “Lockout device” more than a Lockout Lock?

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…...

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Chemical Processes, LOTO, and three (3) program buckets (Simple, Traditional, Complex)

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…...

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LOTO, “Clam Shells”, OSHA, and “substantial”

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…...

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Do “clam shells” comply with OSHA’s definition of “Lockout Device”

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,…...

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