I can remember our first attempt at writing SOPs for our PSM covered process(s):
Deviation is “High Pressure” in V-1
Steps to Correct “High Pressure”:
1) Lower Pressure
Sound familiar? We chuckle now, but in the early 1990’s we thought this was the intent. We still find this kind of PSM/RMP SOP in 2023; however, most businesses have matured beyond this silliness.
But when it comes to LOTO, which is older than the PSM standard, we still find a lot of immaturity in Machine/Equipment-Specific Procedures when verifying each energy source is at a ZES. The most common phrase in the step(s) to verify ZES is…
“Verify zero energy state”
For a step in the process to be so critical, we would hope that the specifics are provided, but in our experience, it is not. So, how specific does our procedure have to be?
| 1910.147(c)(4)(ii)(D) Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures. |