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.
“Affected personnel” are personnel (e.g., machine operators and material handling specialists) who operate or interact with machines that are serviced and maintained pursuant to energy control procedures, as well as that personnel (e.g., general laborers) who are assigned to work in areas where energy control procedures are utilized to service or maintain machinery. In other words, personnel who are assigned to areas where servicing or maintenance work is performed but who do not implement energy control procedures or perform servicing and/or maintenance work need only be trained as affected personnel.
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.
All other employees who may be in an area where energy control procedures may be utilized must receive instruction regarding the energy control procedure and the prohibition against removing a lockout or tagout device and attempting to restart, reenergize, or operate the machinery.
This instruction, which can be provided during new employee orientations, by use of employee handbooks, or through safety meetings, MUST
convey
- what the energy control program does,
- the program’s prohibitions, and
- that the employees are not to touch any locks, tags, energy isolation devices, or equipment covered by this program.
This instruction is required for ALL employees who are not classified as “authorized” or “affected” employees unless the company establishes, communicates, and enforces a policy prohibiting an employee or group of designated employees from ever being in an area where servicing or maintenance is performed pursuant to an energy control procedure. Thus, for example, this training would not be required for an office administrator who is PROHIBITED from going into production areas where all servicing and maintenance activities are performed. On the other hand, this training would be required for a salesperson who rarely goes into production areas but who may go into production areas to discuss product specifications associated with a particular order while servicing or maintenance work may be being performed.
So there we have the definitions/qualifiers for which “LOTO Bucket” our site personnel will fall into. Again, do not think that someone who carries the name/title of “contractor” or “Temp” is somehow not required to be trained under LOTO! If they can come across a lockout/tagoout, then they MUST BE TRAINED TO RECOGNIZE the LOTO! And this takes us full circle back to the OSHA requirement that LOCKS MUST BE IDENTIFIED by either COLOR, SHAPE, or SIZE and once we have established our SINGLE MEANS to identify our Lockout Locks, then ONLY those locks can be used for LOTO. They can not be used for ANY OTHER PURPOSE.