One of my favorite courses to teach is my LOTO Overview course, where I try and convey the OSHA minimum requirements for a functioning Lockout/Tagout (LOTO) program, and each time I do this course I always tell my “water fountain story” from my days at Great Lakes Chemical. My plant manager at GLCC was a stickler for LOTO, and as a ChemE he had an excellent understanding of how LOTO should function in a chemical process. He would be lost in a traditional LOTO program as we see in a manufacturing workplace, but when it came to energy isolation plans for line break, PRCS entry, etc. he was extraordinarily demanding! This is the kind of PM who went to each LOTO training class and kicked it off with his expectations and what would happen if those expectations were not met on each and every LOTO; something we as safety professionals only dream of having that level of support. But shortly after all the training had been completed I was walking down the hallway in the admin building on my way to see the PM for our daily time together, and I passed “Doug”, our #1 maintenance mechanic and just an absolute genius when it came to maintenance. Doug was a great employee and followed every program/practice/procedure to the letter, and he was always helping correct issues with those programs/practices/procedures.
Doug was standing in front of a water fountain as I passed him. I said hi, and like the smart ass, I can be, asked this genius of a man if he needed any help figuring out how the fountain works. We had a chuckle, and I continued on my way down the hallway. As I turned to walk into Dale’s office I noticed that Doug was now on his knees with his flashlight looking under the fountain. My curiosity got the better of me, and I told Dale I would be right back and I returned to the fountain to see what Doug was doing. He looked me square in the eyes and said I am figuring out my “energy isolation plan” so I can lock this thing out and get my line break permit. I chuckled, and you know that look you get from someone when they weren’t kidding and you thought they were… well, I got that look. About that time Dale walks up and asks us “What’s up”; still in shock, I say nothing, and Doug looks over at Dale and says I am figuring out my “energy isolation plan” so I can lock this thing out and get my line break permit. Dale apparently had the same facial response as I did. Doug looked at both of us and said, “what, this is a closed system under pressure, and I have to perform servicing/maintenance that requires me to open the system up and disassemble equipment”… did you not train us this is a LOTO requirement and does our LOTO program not state that clearly?” Hard to argue, and folks Doug was as genuine as they came and he was seriously trying to follow our policies/practices as they were written and he was trained to. So… do your workers lockout water fountains to change their filters?
But the bigger learnings from this… is water a form of hazardous energy?
Yes, that is a loaded question as most people would need more information/data to establish water as a form of hazardous energy that would need to be isolated in order to protect workers. By sheer luck, this week (as I am doing my LOTO training) OSHA issued LOTO citations to a food company for not applying LOTO to water that was 175 degrees F. I think most of us recognize that any solution, vapor, or surface, that is over 140F can cause burns to an adult and thus, water at temperatures above 140F should be considered a form of “hazardous energy”.
What about water pressure?