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…...
LOTO on large complex machinery – LOTO specific procedures (OSHRCS) Read More »
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…...
Does your facility include steam in its Line Break/Equipment Opening Safe Work Practice? Read More »
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…...
Does your LOTO training include some basic ESRWP training? Read More »
While cleaning an auger used to rice potatoes, a 39-year-old production worker found her left arm caught in a running auger. The worker suffered multiple lacerations and a partial amputation of her arm. Co-workers had to cut the auger apart to free her arm. An investigation in September 2020 by OSHA determined that the business…...
A manual ¼ turn ball valve (#1) was the lead isolation valve in a Double Block and Bleed arrangement. The valve handle was incorrectly secured using a run of pipe BELOW the valve. As shown, the valve handle would swing down in order to OPEN the valve. With the chain securing the valve on the…...
Improper isolation of a 1/4 turn ball valve leads to a reportable release of Chlorine Read More »
Scenario: A piece of equipment has twelve (12) energy sources, which must be isolated to get the piece of equipment down to a zero energy state (ZES). I have a task that will expose me to ONLY 1 of these 12 energy sources – can I just lockout the one (1) source or must I…...
Machines with multiple powers sources and I’m exposed to only 1 Read More »
Most facilities will have a piece of equipment that is so large and complex that it will entail isolating many sources of all types of energy in order to get the entire system to a zero energy state (ZES). But what do we do when we have a task that involves exposure to only one…...
Do I have to isolate all the energy sources or can I pick and choose? Read More »
This is SIGNIFICANT for those who truly believe in the purpose and function of OSHA’s LOTO standard. I was never more disappointed in an ALJ than after they decided to vacate such a clear violation of LOTO. I may have even said, “Why do lawyers/judges make for bad safety professionals.” This fatality involved an apprentice…...
The Eleventh Circuit reinstates OSHA’s LOTO Citation regarding a contractor death Read More »
Have you ever been told… “it moves too slow to be a hazard”? If you stay in the safety profession long enough, you will be presented with this viewpoint. But LOTO is NEVER about how slow something moves; there is no exemption in the standard for such a thing. Here is a case we can…...
LOTO is NEVER based on how “slow it moves”, even when it is 1 revolution/10 minutes Read More »
This is a written explanation of how I was taught to perform Group Lockout and how to manage contractors working on-site under a Group Lockout. There are many things in this document that are NOT required by OSHA; however, they are in the program to ensure compliance with OSHA’s minimum expectations. We did it this…...
My Group Lockout – Lockbox method Read More »
If we had a dime for each time we get pushback on the most fundamental aspect of Lockout/Tagout (LOTO), we could all retire! NEVER is an authorized employee allowed to work under someone else lock – PERIOD! When servicing and maintenance that requires LOTO is performed, then EACH authorized worker MUST HAVE EXCLUSIVE CONTROL of…...
If you have equipment that uses compressed air (CA) as an energy source, you will understand my frustrations with how poorly we manage this hazardous energy source. Typically, compressed air is provided via a plant-wide header system with drops for machine/equipment. These drops will then use a hose to deliver the compressed air to the…...
The tale of two LOTOs – worlds apart (Compressed Air) Read More »
