OSHA says we are to have machine-specific LOTO procedures (note that there is an exception to this requirement, but in my scenario, it is not relative). In these procedures, we have to identify the following:
- the types of energy,
- their magnitudes,
- the means/methods to isolate and
- the means/methods to verify zero energy state (ZES) for each source
Suppose you or I go out to do our periodic LOTO inspection, and we take the LOTO procedure for the machine that gets locked out at least five times a week for QC cleaning. Should we not expect the machine’s operator(s) to know the procedure well enough to answer questions?
For example, a steam line goes to the equipment. The procedure says to close valve S-1, and S-1 is labeled in the field. I close it and apply a LOTO lock. The procedure’s next step is verifying zero energy on the steam, but the procedure does not state how this will be done. Operator(s) cannot answer how they do this task each time they lock it out.
There is also NO STEP requiring the “bleeding of steam” after the locked valve. When asked, the operator claims they follow the procedure, which takes me back to “how do you do the verification” since you follow the procedure to the letter. This procedure has also been “audited several times,” and no issues were found.
Is it too much to ask that the machine-specific procedure be detailed enough that:
- we use valve numbers and specifically spell out which valves are to be used for isolation
- we specifically say what pressure gauge or start/stop switch to use to verify zero energy
Having a machine-specific procedure, in my opinion, falls short when we say “verify zero energy” and do not have a specific method in which to do so.
How do you all do it?
What do your machine-specific procedures call out regarding zero energy state verification?