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 […]
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
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
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
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
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
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
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
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
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,
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
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
