Way back in April 2016, the OSHRC published a decision that settled the argument about LOTO procedures for “specific equipment/machines” and what they must contain. This important decision helped settle a lot of scuttlebutt about how LOTO gets managed in “complex” situations. I like to explain to clients that LOTO in a chemical process is managed differently than how it is managed at a traditional manufacturing facility. I put LOTO into three (3) buckets:
1) Simple LOTO
2) Traditional LOTO
3) Complex LOTO
Using 29 CFR 1910.147 as our road-map we can clearly see how these three (3) buckets play out.
1) Simple LOTO
“Simple LOTO” is a phrase used to describe the LOTO that OSHA discusses in 1910.147(c)(4)(i), where they exempt the facility from having to have a written machine/equipment-specific LOTO procedure. When the equipment meets ALL of the following eight (8) criteria, we call this a “SIMPLE LOTO”:
(1) machine/equipment has no potential for stored or residual energy or reaccumulation of stored energy after shutdown;
(2) machine/equipment has a single energy source that can be readily identified and isolated and will completely de-energize and deactivate the machine or equipment;
(4) machine/equipment is isolated from that energy source and locked out during servicing or maintenance;
(5) single lockout device will achieve a locked-out condition;
(6) lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
(7) the servicing or maintenance does not create hazards for other employees; and
(8) in utilizing this exception, the employer has had no accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance.
2) Traditional LOTO
The “Traditional LOTO” is what 1910.147 was written for. When they wrote the standard, OSHA was not thinking about chemical plants/process areas. I can’t help but think they were thinking of the “Big 3” Auto Makers when writing the standard. The standard is easily applied in the traditional manufacturing setting. Writing “machine/equipment” in this type of workplace is manageable and quite easy as the equipment falls somewhere between the “simple LOTO” and “complex LOTO” discussed below.
3) Complex LOTO
These LOTOs would require an energy isolation plan to be generated based on the scope of work, energy types, and magnitudes. For example, a chemical process unit has 1,000 valves. Applying 1910.147 in the strictest of terms, we would be required to have a “specific” LOTO procedure for each valve in the process, and doing so would make the LOTO program unmanageable. However, just because we have a “complex” situation, we are not exempted from having a WRITTEN energy control plan that identifies ALL the energy types, their magnitudes, the means/methods to isolate each source, and the means to verify each source is at a zero energy state (ZES), from preparing an energy control plan for changing out a valve to preparing an energy control plan for isolating a Permit-Required Confined Space that could involve dozens of energy isolating devices.
So in the PSM/RMP world, our LOTOs will fit into one of these three buckets, and our written LOTO program should address how we define these three buckets and how we will manage the three buckets.