WOW… my LOTO ppt for “Affected Personnel” that I posted earlier this week has caused quite the “back and forth” with too many people/sites. I just assumed that we had a basic understanding of “who falls into the “affected” bucket” and “what they must know”. Affected employees do NOT need to attend a 2-hour training course – you can take that to the bank – don’t care how many CSHO’s have told you otherwise!!! We should be able to train BOTH the “affected” and “others” in about 15-20 minutes as all we have to ensure is that they:
- Recognize LOTO devices immediately;
- Recognize when the energy control procedure is being used;
- Understand the purpose and use of the procedure; and, most importantly; and
- Understand the importance of not tampering with a lockout or tagout devices and not starting or using equipment that has been locked out or tagged out.
Heck, my ppt goes even one step further in that I believe that “affected” and “other” personnel MUST FULLY understand their LIMITATIONS when they are NOT an “authorized” individual. In other words, we need to ensure that these workers know they are NOT allowed to remove/open guards or bypass/defeat safety devices to perform “servicing and maintenance” tasks, including CLEANING and UNJAMMING. It is up to each worksite to establish its “minor servicing exception” management system (e.g., how are these “minor servicing tasks” are ID’ed, evaluated, and managed). Still, the ONLY time an “affected personnel” will EVER remove/open a guard and place any part of their body into a hazard zone of the machine (i.e., the area that was protected/guarded!) is when the task has met the five (5) criteria for “minor servicing”:
- Part of NORMAL PRODUCTION
- Routine
- Repetitive
- Integral
- No Disassembly involved
AND they are fully protected with alternative means such as a properly designed/installed/maintained INTERLOCK on the guard/door.
BOTTOM LINE… Affected employees are required to be instructed in these matters and be informed that disregarding or violating the prohibitions imposed by the energy control procedure could endanger their own lives or the lives of their co-workers. (SOURCE: OSHA CPL)
Here is the rest of the discussion from OSHA regarding “affected” and “other” workers under our LOTO program. I have STOPPED using the terms “affected employees” because so many workers these days are “contractors” or “temps,” and too many businesses want to attempt to exclude them from LOTO since their job titles don’t match OSHA language… DONT BE A MORON and think that merely because OSHA chose to call workers “affected employees” and the company uses a different name somehow excludes the worker from serious risk.