Lockout Tagout

Clarification on Group LOTO requirements

Seriously, in the year 2021/2022, we still have these questions asked of OSHA about a standard that has been in place since the mid-1980s. Scenario 1: Three (3) authorized employees are working on a pump. Each energy source is de-energized and locked out by an employee in plant operations. Then, the plant operations employee places…...

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Energy isolation requirements for pneumatically powered control valves

OSHA once again clarifies that locking out the air source to a pneumatically powered control valve is NOT locking the energy isolation device!  When I taught at ASSP Seminarfest several years ago, the most disputed point was this very practice.  I was very clear, which did not sit well with some attendees, that locking the…...

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Rotary Valve/Airlock and Lock-Out/Tag-Out Hazards (OSHA SHIB 2021)

Rotary valves/airlocks (rotary valves) are devices with close-fitting, revolving blades/vanes installed inside industrial equipment to control the flow of materials through a process (see Figure 1).  Rotary valves are used in many industries and functions. A common example (Figure 2) is an airlock used in a pneumatic conveying system to dispense material while maintaining system…...

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Don’t say it is “locked out” when the isolation devices on the energy soures are NOT locked in their safe positions

At 8:00 a.m. on March 15, 2021, Employee #1 removed, cleaned, prepared the surface and replaced the blow-in door gasket seals on the USS McFaul. The door was TAGGED OUT in the OPEN position; however, in this position, the pneumatic pressure and electric power could NOT be secured in its SAFE POSITION. While performing the…...

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Stored energy fatality (Air compressor/dryer)

At 1:15 p.m. on 11/3/2020, a worker employed by an HVAC company, was working at a customer’s commercial facility. He was in the process of removing a coupler and blind from the intake header of an air dryer. The employee did NOT first relieve the air pressure from the header…. Membership Required You must be...

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Stored energy fatality (NG compressor)

At 9:45 a.m. on December 11, 2020, an employee was preparing to do maintenance on a natural gas (NG) compressor. The compressor was not prepared for maintenance correctly (e.g., not LOTO’ed properly), pressure built up, and an engine cap struck the employee on the head…. Membership Required You must be a member to access this...

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Does Double Block and Bleed require INDEPENDENT isolation points?

In the 90s, I was working a turn-around at a sister facility and learned the niftiest trick related to Double Block and Bleed (DB&B).  When the isolation valves and the bleed valve were nearby (i.e., a couple of feet or less) of each other, they would use just a single lock to secure the isolation. …...

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OSHA issues Serious and Willfuls for LOTO @ supermarket chain ($339K)

A worker at a milk packaging plant operated by a large supermarket chain lost four fingers while operating a molding machine that lacked the required safeguards.  OSHA investigated the Feb. 12 incident and cited the business for two (2) willful and five (5) serious violations and one (1) other than serious violation for: Failing to…...

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Should we apply our Line Break and Equipment Opening safe work practice to utilities such as steam? (Double Fatality w/ Steam release)

Line Breaking and Equipment Opening (LEO) hazards are oftentimes not well recognized or respected, even in PSM/RMP-covered processes.  Once we are removed from a “covered process,” the lack of recognition and lack of respect only increases.  But in my career, some of the more serious accidents involving LEO on lines/equipment did NOT involve processes covered…...

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Should we apply our Line Break and Equipment Opening safe work practice to utilities such as steam? (Double Fatality w/ Steam release) Read More »

LOTO on large complex machinery – LOTO specific procedures (OSHRCS)

This is a fascinating case, as the OSHRC has upheld this citation, although they significantly reduced the $ and made it “other-than-serious.” But again, I disagree with this case, as the workers appeared to have been protected during the belt change; they did not follow the LOTO procedure, which I believe was “lazily written.” This…...

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Does your facility include steam in its Line Break/Equipment Opening Safe Work Practice?

At 6:52 p.m. on August 10, 2020, three (3) employees attempted to remove a clog from a hydrolyzed. A hydrolyzed apparatus is used to conduct the hydrolysis reaction in starch. The employees were unable to get the steam to release from the pressure vessel. Employee #1, a senior maintenance worker, made the decision to open…...

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Does your LOTO training include some basic ESRWP training?

In a lot of older plants, personnel who are locking out equipment are not granted the convenience of a “local electrical disconnect,” meaning they have to use what I call “knife disconnects” such as this: Or do we make the qualified electrical workers the “gatekeepers” of all electrical LOTO, and thus only they operate these…...

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