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Parent Category: Safety Info Posts

Category: Lockout Tagout

Published: 28 July 2019

Since I shared my article last week on OSHA's position of NOT allowing "exclusive control" to be carried over to process valves like we do with "cord and plug" electrical equipment, my international friends and clients have been having quite the chuckle at us here in the USA.  They all say virtually the same thing... "you guys sure do make something so simple, very difficult".  Those of you that read my article and my position of what is declared "exclusive control" saw that I interject "risk assessments" into my Energy Isolation Control Plans, as this is how I was taught very early in my career.  We did not have OSHA's PRCS standard for several years when I started my career in the petrochem industry and thus we had to devise some other "standards" to ensure safe entry into our spaces.  Having worked for several international companies, my corporate safety standards tended to have some really nice "international practices" sprinkled into them and I absolutely loved them as they were ALWAYS RISK-BASED - not the typical OSHA minimums approach.  For example, The UK's Health and Safety Executive (HSE) published their guidance on "safe isolation of plant and equipment" (HSG253).  For those of you that have been interacting with me for 20 years know I have raved about this publication many times; it is the BEST guide for the "process industry" to understand how we MUST isolate our hazardous forms of energy and how different LOTO is for us then say an assembly style manufacturing plant.  My good friends at The HSE were quick to remind me this weekend of this publication and in it, you will see where I got my rationale for my debate on "exclusive control" and why I am such a fanatic when it comes to the use of Double-Block-Bleed arrangements, rolling spool pieces, and blanking/blinding.  This HSE document SEMI-QUANTIFIES the risks and provides us with the PROPER ISOLATION means to ensure our energy isolation method(s) are adequate for the hazardous form of energy and the work taking place (including the location of the work!).  In this presentation an HSE HM Specialist Inspector (Mechanical) walks us through the Risk Assessment process to establish the minimum level of energy isolation -  for those of you who love LOTO, this is about as sweet as it can get in our profession (IMHO)...

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