LOTO

Line Break Gone Bad (boiler circulation pump)

We say this for so many of these maintenance tasks… LINE BREAK PERMIT brings so much safety to maintenance work that it should extend well beyond PSM/RMP-covered processes. The Safe Work Permitting process, when developed, implemented, and managed PROPERLY, will go a long way to reduce the chances of this type of accident. At approximately…...

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Equipment Opening Gone Bad (NAOH)

At 4:15 p.m. on December 6, 2021, a contractor, 26, removed transmitters from tanks to winterize the facilities. As the employee removed the bolts and loosened the transmitter from a tank, the contents (50% concentration of Sodium Hydroxide) sprayed out and onto the employee’s eyes, face, head, and chest (upper torso). The employee attempted to…...

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LOTO Safety Myth #4 – Contractors

1910.147 says the following regarding contractors performing LOTO inside our facilities: 1910.147(f)(2)(i)Whenever outside servicing personnel are to be engaged in activities covered by the scope and application of this standard, the on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures.1910.147(f)(2)(ii)The on-site employer shall ensure that his/her employees…...

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CSB Update on Fatal H2S Release @ TX Refinery

Interesting facts about this event: On October 10, 2024, at 4:23 p.m., approximately 27,000 pounds of hydrogen sulfide gas were released during maintenance at the Refinery in Deer Park, Texas. The release fatally injured two (2) contract workers. Background Information The facility is a petroleum refinery located in Deer Park, Texas and is a Limited…...

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How many locks do we need to Lockout a Double Block & Bleed arrangement

Several clients design Double Block and Bleed (DB&B) isolation into their process, especially when they know they will regularly enter certain Permit-Required Confined Spaces (PRCS). When these DB&B arrangements are part of the design, the isolation valves and the bleed valve are near one another. This allows us to use a single lock with some…...

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LOTO Safety Myth #3 (Training/Inspections)

We often encounter an organization that conducts LOTO training annually. They do this because they believe OSHA requires annual LOTO training. However, the standard, 1910.147, does NOT require annual training! The standard requires each authorized employee to be “inspected” annually. If they fail that inspection, the standard requires the authorized employee to be re-trained. OSHA…...

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LOTO Safety Myth #2 (Minor Servicing Exception)

Many folks will focus on ONLY three (3) criteria for applying this “exception” to OSHA LOTO standard 1910.147. And these (3) criteria are just opening the gates to LOTO Hell. Far too often we find the “exception” has become the rule and LOTO has become the exception. So what are the FIVE (5) criteria we…...

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LOTO Safety Myth #1

I have written dozens of articles around these “safety myths”, but Jonathan Zimmerman and I were not selected to present this at ASSP several years ago so I thought I would share it as a series here. These are topics that I still get challenged on in 2024/2025 and often I am unable to convince…...

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Learning Opportunity vs Discipline

There’s a massive difference that may require massively different approaches in how we respond to failures in administrative controls such as LOTO. Scenario #1: a worker with less than a year of experience, is tasked with isolating a PRCS that has 29 isolation points. It was his first time to do this isolation and was…...

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When will the ammonia refrigeration industry finally embrace LOTO? (Part I)

By: Victor Dearman Jr. CIRO, CRST Flagging tape is not LOTO! And never has been. I would bet good money the operating procedure for this compressor has LOTO covered, but those are just documents to look good in a binder sitting on a shelf collecting dust because they are viewed as a necessary evil to…...

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Line Break Gone Bad (Flammable Gas)

At approximately 9:20 a.m. on December 1, 2010, Employee #1, #2 and #3 were working on the barge of an oilrig (Rig Number 1). They were removing a Christmas tree flange, an assembly of valves, spools, and fittings used to control the flow of oil or gas out of the well, with a cutting torch…....

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Steam belongs in our Line Break Program

At 9:00 a.m. on October 6, 2019, an employee was attempting to open a flange. Steam released, burning the employee’s legs and lower body. The employee was hospitalized. 29 CFR 1910.269(d)(2)(iv)(D): The procedure did not clearly and specifically outline specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout…...

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