Lockout Tagout

Fatal flaw in OSHA’s “Periodic Inspection” requirements

We are all familiar with OSHA’s LOTO Periodic Inspection requirements (1910.147(c)(6)).  It is a topic of great debate, still in the Year 2023.  But there is a serious, I say it is a fatal flaw in the periodic inspection process. It is common for this activity to be performed by managers/supervisors who are authorized in…...

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KY OSHA does not allow Tagout when the device can take a lock

I am not trying to start another LOTO fight about Lockout vs Tagout, but for those who do work in the state of KY, it is important to know that KY-OSHA does NOT allow an employer to utilize TAGOUT when the device can accept a lock.  This is different than what Federal OSHA allows.  Federal…...

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A detailed look at OSHA’s 2022 LOTO citations

In OSHA’s fiscal year 2022, the agency issued over 3,800 LOTO citations. Here is a breakdown of those citations… Top 10 by # of Citations Top 10 by Citations $ Full listing of Citations with Number of Citations and $… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tagout) Program (NIOSH)

Employers are required by 29 CFR* § 1910.147(c)(6) to conduct a periodic inspection of written hazardous energy control (lockout/tagout) procedures.  The inspection must be performed at least once annually [per 12-month interval, as stated in 1910.147(c)(6)(i)] because of the significant risks associated with inadequate energy control procedures or the failure to properly implement them [OSHA…...

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The horrors of improper LOTO

When workers say to me, “that hardly ever happens” I just shake my head.  It happens far more often than most people think.  I mean, think about why did OSHA promulgate the LOTO standard – people were turning on machines with workers inside.  But this case was exceptionally bad!  A father found his son inside…...

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LOTO Fatality (Interlocked Protected Area)

A 48-year-old male employee was crushed inside a machine (COS) while adjusting the grippers that place lead cells into batteries. This employer is a battery manufacturer. On the day of the incident, the victim was called by the machine operator to troubleshoot the COS machine because the grippers were not working. It was determined that…...

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Line Break gone bad (boric acid and zinc oxide)

At 10:15 a.m. on February 16, 2022, Employee #1, 27, removed a flange from an overhead pipe as part of a multi-employer pipe replacement project. He was not aware that a different pipeline had been locked out. A heated slurry solution of boric acid and zinc oxide was released from the pipe he was working…...

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Hazardous Energy – visual display of PSI

If you have ever taught a LOTO course, you know that you will always get the questions… “Is ___ psi a hazardous energy source?”.  Regardless of the gas’s inherent hazard(s), we should always answer by saying “Zero = Zero,” and in LOTO, we are required to achieve a zero energy state.  So, any psi of…...

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Why being “Authorized” means something in LOTO

How did you spend your Friday night and Saturday?  Me?  I spent mine helping a client manage a traumatic injury to a new employee with less than 3-weeks on the job.  And like most employers, this company truly cares about their employees and honestly wants the best for their employees.  This business may be the…...

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A supervisor’s LO lock and a roster do NOT meet 1910.147

Why so many try to make such a simple safety process so difficult has puzzled me for years!  Even in Group LOTO, each employee is protected by the LOTO MUST have EXCLUSIVE CONTROL of the devices protecting them.  It is that simple.  This organization should be embarrassed for asking these questions, especially when their scenarios…...

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Cracking a flange with stored steam energy kills two maintenance techs (OSHRC)

World-class safety can be summed up in this manner… The ability to recognize a serious hazard that can be controlled by an existing safe work practice that is in place for complying with a different OSHA standard.  If you’re a process safety engineer/practitioner you have dealt with “line break/process opening” for your Highly Hazardous Chemicals…...

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Fatality inside mulch coloring machine (LOTO)

At 6:05 p.m. on March 3, 2021, an employee, 27, was clearing jammed mulch from a mulch coloring machine. The employee disconnected the power from the machine, entered the hopper, and began removing mulch. The employee exited the hopper, restored power, and restarted the machine. The employee reentered the machine a second time WITHOUT DISCONNECTING…...

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