I can remember our first attempt at writing SOPs for our PSM covered process(s): Deviation is “High Pressure” in V-1 Steps to Correct “High Pressure”: 1) Lower Pressure Sound familiar? We chuckle now, but in the early 1990’s we thought this was the intent. We still find this kind of PSM/RMP SOP in 2023; however,…...
Verifying ZES requires SPECIFIC procedure(s) Read More »
From MSHA accident file… The two (10) ten-inch metal pipes being removed were part of a closed-loop chiller system that had been abandoned. One pipe supplied chilled water underground (supply and shown as blue in the drawing), and the other returned water to the surface…...
When gravity and water work together to become a “hazardous form of energy” Read More »
We are seeing more and more of this type of set-up, where an auxiliary piece of equipment on an assembly/production line has two (2) electrical supplies. One is from the main SWITCH on the line, and one is from a separate source. This is usually done when the auxiliary equipment may need to stay energized…...
LOTO, “Energy From More Than One Source”, and critical labeling Read More »
Most facilities will have a few pieces of equipment that require using a dozen or more energy isolation devices to achieve a full LO’ed situation. Most businesses, at least early on in their implementation of LOTO for these pieces of equipment, will state ALL energy isolation devices will be utilized regardless of the scope of…...
In a mature LOTO program, “SCOPE of WORK” matters Read More »
Have you ever seen a setup on a machine, typically those manufactured outside of the USA, with two (2) electrical disconnects? Most of the time, these disconnects are COLOR-CODED to clearly identify their different uses, although we have seen some that were NOT color-coded, nor were they properly labeled! Here is an example of what…...
Motor disconnect vs. Main disconnect Read More »
Whenever we talk about OSHA’s Lockout/Tagout (LOTO) standard, we almost always have to talk about its machine guarding and electrical standards. One crucial requirement in OSHA’s electrical standards, as it relates directly back to LOTO, is … (emphasis by me)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...
How electrical standards play a role in LOTO practices Read More »
I don’t think many safety pros would argue with this statement: LOTO requires that all forms of hazardous energy be taken to a ZES before servicing and maintenance begin. But I have had many discussions about DEFINING and QUANTIFYING what a “hazardous form of energy” is. Since OSHA has not quantified the term “hazardous energy”,…...
If we look close enough, we can see OSHA’s approach to some of its more extensive standards through the lens of its fitting into a formal Safety Management System. The Control of Hazardous Energy (e.g., Lockout/Tagout) standard is one of these standards. Using the old Plan→Do→Check→Act SMS model, we can breakdown 1910.147 into this model,…...
Viewing OSHA’s Control of Hazardous Energy through the lens of an SMS Read More »
Today’s MSHA Fatality Report made me wonder how many LOTO programs require the SECONDARY SECUREMENT of large objects, even after the power source that normally moves the equipment has been locked out. For example, cooling towers and condenser fan blades. I have experienced firsthand a piece of equipment two times involved were very large fan…...
LOTO programs and the SECONDARY SECUREMENT of large objects Read More »
Earlier today, I shared my thoughts on a critical safety step that is often not part of LOTO periodic inspections involving qualified electrical workers. That article spurred a conference call with a client this afternoon. That discussion led to the next layer of the proverbial onion being peeled back… Who should be responsible for managing…...
Volt meter management matters in ESRWPs! Read More »
Scenario: You’re out and about, and you come up on two workers working on a piece of equipment. You stop and engage the two workers on their energy isolation for their work. One of the workers operates the machine and has it locked out as part of his end-of-shift cleaning tasks. The other worker is…...
There is an evil myth regarding LOTO training and Periodic Inspections. I recently had a lengthy discussion with a Labor Lawyer regarding the FACT that annual LOTO training does NOT satisfy the Annual Periodic Inspection requirements. An employer is NOT required to perform annual training on LOTO, but they are REQUIRED to conduct a periodic…...
Annual LOTO training does NOT satisfy the Annual Periodic Inspection requirements Read More »
