As we have discussed, the “note and exception” that goes with 1910.147(c)(4)(i) is what I call “simple lockout”; however, I have always stated it was intended for simple electrical lockouts, seeing how one of the hurdles to using the exception was that there could be no “stored energy.” So, when we look at the eight…...
Once we get to the place where we can agree that fluids and gases are “stored energy” and that those “stored energies” have to be bled/drained to achieve a Zero Energy State (ZES), we can then discuss the potential hazards these necessary actions can create. I have written a lot about using 1/4 turn ball…...
Last month, I wrote Before we can achieve a ZES, we must first define and quantify what precisely a form of “hazardous energy” is, and this week, I posted the MSHA accident investigation report where water in an abandoned chilled water system 1600′ underground was opened and the water, pressurized by the head pressure alone,…...
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,…...
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…...
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…...
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…...
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…...
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?...
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,…...
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…...
