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…...
In the year 2023, we still get the old questioning of the intent of LOTO. It never fails; in our LOTO training, we will get operators repeating the application of LOTO to their jobs, word for word, as I have stated it, and then comes the $60,000 question… Does my boss know about this? Another…...
Management should make LOTO easy and efficient Read More »
A cleaning crew member, with no electrical qualifications, switched on a high voltage (2200V 3Ph) electrical switch for a piece of equipment after it had been locked out. The worker’s hand was burnt by escaping arc gasses and flames coming through a damaged door gasket. The equipment has a 2100-volt ac synchronous motor that is…...
Hazards of returning machinery to operation after LOTO Read More »
Without a doubt, the biggest LOTO failure for businesses with a LOTO program is the application of the “minor servicing” exception. (emphasis by me) 1910.147(a)(2)(i) This standard applies to the control of energy during servicing and/or maintenance of machines and equipment.1910.147(a)(2)(ii) Normal production operations are not covered by this standard (See subpart 0 of this…...
Evaluating the application of and the controls associated with “minor servicing” Read More »
