I was recently involved in a safety review at a client with two (2) separate LOTO failure events in a month. I know this client and the PM very well, and I was never more disappointed in their decisions about the discipline around these two (2) very different LOTO events. One event resulted in NO…...
These requirements control the release of hazardous energy while workers service, maintain, or repair machines or equipment when activation, start-up, or release of energy from an energy source is possible; proper control of hazardous energy prevents death or serious injury among these workers. Energy Control Procedure (paragraph (c)(4)(i))… Membership Required You must be a member...
OSHA breaks down some key parts of its LOTO standard Read More »
Managing our LOTO program requires considerable resources, and it requires a team approach! However, we see many failed attempts to control hazards through a facility’s LOTO program. One of the most common failures is how “authorized employees” are defined in terms of the skills they are trained on. Which Rabbit Hole you choose to go…...
How do you define the scope of “Authorized Employees” Read More »
I put this image together for a friend struggling to demonstrate to their management that we can not discuss LOTO until Machine Guarding is in place. These two topics go hand in hand and trust me; if there are guarding issues, those hazards will be compounded when we attempt to frame up the LOTO program…....
Guarding comes BEFORE LOTO Read More »
Last month, I discussed what a “management system” would look like should we manage our Permit-Required Confined Space entry operations as a “management system” versus a standalone OSHA compliance program. (CLICK HERE for that post) Today, I want to discuss the same approach but in respect to how we manage another life safety critical practice……...
On August 23, 2023, an employee was troubleshooting an unscrambler machine malfunction. The employee walked around to the bottom of the support frame of the machine, near two parallel drive chains. A coworker restarted the machine, and the employee was pulled into the machine by the drive chains. The employee was killed. Source: https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1693870.015… Membership...
It happened again… coworker turns on machine that a worker was “trouble-shooting” Read More »
In this Letter of Interpretation (LOI), OSHA answers several common questions related to the practice of Group Lockout, such as: Does OSHA require all authorized employees who place their locks on the group lockbox to verify that the energy source was deenergized before performing servicing and maintenance work? How could a change of condition(s) (e.g.,…...
OSHA answers several questions related to “Group LOTO” practices Read More »
Information regarding OSHA Minor Servicing while working in General Industry. The OSHA standard states: 1910.147(a)(2)(ii)(B)An employee is required to place any part of their body into an area on a machine or piece of equipment where work is performed upon the material being processed (point of operation) or where an associated danger zone exists during…...
One thing that many find confusing regarding the control of hazardous energy is the actual hazard they are trying to render to a Zero Energy State (ZES). This is a simple concept, but many get it wrong in their programs and machine-specific procedures. Let’s take compressed air as an example. Many compressed air systems in…...
Lockout is a life-critical program/process/procedure(s). Our efforts to VERIFY that the program/process/procedures meet our needs is a CRITICAL path in the LOTO process. OSHA recognized this when it promulgated its Control of Hazardous Energy standard (1910.147). Specifically, 1910.147(c)(6) “Periodic Inspections” requires the employer to verify the program/procedures and that the employees can properly apply them…...
Periodic Inspections should be SIMPLE and straightforward Read More »
This is a HIGH-LEVEL overview of the many types and levels of energy isolation means and methods. This is not widely recognized in the USA, but those businesses advanced in energy isolation/control plans use this approach. The key to this success is to incorporate these methods into process designs. Members can download…...
Energy Isolation Methods: Positive – Proved – Non-Proved Read More »
NOTE: I totally disagree with this ALJ decision; however, I give him much credit as I listened to the witnesses and followed the evidence he had presented. This amputation injury was a LOTO violation in my eyes, and I would have argued this case differently. But here are the facts presented to the Judge: what…...
