This posting is a demonstration as to how OSHA (State of IN OSHA) can/will issue citations against BOTH the host facility and it’s contractor for the same OSHA violations. In this case, the contractor doing the work, did so using TAGOUT without any additional measures that would make “tagout” equally effective as “lockout” (e.g. Tag +). Below are the exact same citations issued to both the host and its contractor…
Host Facility Citations
Safety Order 01 Item 001
Type of Violation: Serious; $5,000
29 CFR 1910.269(d)(2)(ii)(B)(1): When a tagout device was used on an energy isolating device capable of being locked out, the employer did not demonstrate that the tagout program provided a level of safety equivalent to that obtained by the use of a lock:
2B Bunker Dust Collector Unit #2 on 10th-floor – Maintenance employees performing preventative maintenance on the dust collectors including such as, but not limited to, monthly inspections for buildup on the impellers were using tags instead of locks to control hazardous energy. The tagout system did not provide full employee protection in that no additional safety measures other than applying a tag were taken to protect employees from hazardous energy.
OR IN THE ALTERNATIVE
29 CFR 1910.147(c)(2)(ii): If an energy isolating device is capable of being locked out, the employer’s energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section:
2B Bunker Dust Collector Unit #2 on 10th-floor – Maintenance employees performing preventative maintenance on the dust collectors including such as, but not limited to, monthly inspections for buildup on the impellers were using tags instead of locks to control hazardous energy. The tagout system did not provide full employee protection in that no additional safety measures other than applying a tag were taken to protect employees from hazardous energy.
Safety Order 01 Item 002
Type of Violation: Serious; $5,000
29 CFR 1910.269(d)(3)(ii)(E): Each lockout device or tagout device did not include provisions for the identification of the employee applying the device: 2B Bunker Dust Collector Unit #2 on 10th-floor – Maintenance employees performing preventative maintenance on the dust collectors including such as, but not limited to, monthly inspections for buildup on the impellers were using tagout devices that did not identify the employee applying the tagout device.
OR IN THE ALTERNATIVE
29 CFR 1910.147(c)(5)(ii)(D): Lockout devices and tagout devices shall include the identity of the employee applying the device:
2B Bunker Dust Collector Unit #2 on 10th-floor – Maintenance employees performing preventative maintenance on the dust collectors including such as, but not limited to, monthly inspections for buildup on the impellers were using tagout devices that did not identify the employee applying the tagout device.
Safety Order 01 Item 003
Type of Violation: Serious; $5,000
29 CFR 1910.269(d)(5)(ii)(D): Each authorized employee did not affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she began work:
2B Bunker Dust Collector Unit #2 on 10th-floor – Maintenance employees performing preventative maintenance on the dust collectors including such as, but not limited to, monthly inspections for buildup on the impellers were only applying one tagout device to each energy source when multiple employees were performing servicing and maintenance. The single tag did not identify the persons working on the equipment.
OR IN THE ALTERNATIVE
29 CFR 1910.147(f)(3)(ii)(D): Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockout box, or comparable mechanism when he or she begins work and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained:
2B Bunker Dust Collector Unit #2 on 10th-floor – Maintenance employees performing preventative maintenance on the dust collectors including such as, but not limited to, monthly inspections for buildup on the impellers were only applying one tagout device to each energy source when multiple employees were performing servicing and maintenance. The single tag did not identify the persons working on the equipment.
Contractor’s Citations
Safety Order 01 Item 001
Type of Violation: Serious; $5,000 29CFR1910.269(d)(2)(ii)(B)(1): When a tagout device was used on an energy isolating device capable of being locked out, the employer did not demonstrate that the tag out program provided a level of safety equivalent to that obtained by the use of a lock:
29 CFR 1910.269(d)(2)(ii)(B)(1): When a tagout device was used on an energy isolating device capable of being locked out, the employer did not demonstrate that the tag out program provided a level of safety equivalent to that obtained by the use of a lock:
2B Bunker Dust Collector Unit #2 on 10th-floor – Employees performing cleaning operations such as, but not limited to, water blasting coal dust on Duke Energy dust collector impellers relied on tagout devices applied by Duke Energy to control hazardous energy. The tagout system did not provide full employee protection in that no additional safety measures other than applying a tag were taken to protect employees from hazardous energy.
OR IN THE ALTERNATIVE
29 CFR 1910.147(c)(2)(ii): If an energy isolating device is capable of being locked out the employer’s energy control program under paragraph (c)(l) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section:
2B Bunker Dust Collector Unit #2 on 10th-floor-Employees performing cleaning operations such as, but not limited to, water blasting coal dust on Duke Energy dust collector impellers relied on tagout devices applied by Duke Energy to control hazardous energy. The tagout system did not provide full employee protection in that no additional safety measures other than applying a tag were taken to protect employees from hazardous energy.
Safety Order 01 Item 002
Type of Violation: Serious; $5,000
29 CFR 1910.269(d)(6)(v): Following the application of lockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy was not relieved, disconnected, restrained, or otherwise rendered safe:
2B Bunker Dust Collector Unit #2 on 10th-floor – Employees performing cleaning operations such as, but not limited to, water blasting coal dust on Duke Energy dust collector impellers did not restrain or render the auger safe before introducing pressurized water, which caused the fan auger to rotate once it was clear of debris.
OR IN THE ALTERNATIVE
29 CFR 1910.147(d)(5)(i): Following the application of lockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe:
2B Bunker Dust Collector Unit #2 on 10th-floor – Employees performing cleaning operations such as, but not limited to, water blasting coal dust on Duke Energy dust collector impellers did not restrain or render the auger safe before introducing pressurized water, which caused the fan auger to rotate once it was clear of debris.
Safety Order 01 Item 003
Type of Violation: Serious; $5,000 29 CFR 1910.269(d)(8)(ii)(D): Each authorized employee did not affix a personal lockout or t
29 CFR 1910.269(d)(8)(ii)(D): Each authorized employee did not affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she began work:
2B Bunker Dust Collector Unit #2 on 10th-floor – Employees performing cleaning operations such as, but not limited to, water blasting coal dust on Duke Energy dust collector impellers did not apply an individual lock or tagout device to each energy source.
OR IN THE ALTERNATIVE
29 CFR 1910.147(f)(3)(ii)(D): Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockout box, or comparable mechanism when he or she begins work and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained:
2B Bunker Dust Collector Unit #2 on 10th-floor – Employees performing cleaning operations such as, but not limited to, water blasting coal dust on Duke Energy dust collector impellers did not apply an individual lock or tagout device to each energy source.
CLICK HERE for the Contractor’s Citations
CLICK HERE for the Host Facility’s Citations