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Typical Minimal Lockout/Tagout Procedures

industrial safety-loto
Safety Lockout/Tagout Best Practices

Written by Steve Hudgik

OSHA Standard 1910.147 Appendix A provides a minimal lockout/tagout procedure that can be used as a guide for writing an OSHA compliant lockout/tagout procedure. This sample procedure covers lockout. When an energy isolating device is not lockable tagout may be used, provided that you comply with the OSHA requirements for additional training and more rigorous periodic inspections.

Lockout/Tagout Procedures - Using Tagout For A Lockable Device

If an energy isolating device is lockable, but tagout is used, the following must be done:

  • The tagout device must be attached at the same location that the lockout device would have been attached
  • The employer must demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.
    • the employer shall demonstrate full compliance with all tagout-related provisions of OSHA 1910.147 together with any additional elements as are necessary to provide the equivalent safety available from the use of a lockout device. Additional means to be considered as part of the demonstration of full employee protection shall include the implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.
  • Provide additional training.
  • Provide more rigorous periodic inspections.
  • For more complex systems, more comprehensive procedures may need to be developed, documented and utilized.

Lockout/Tagout Procedures - Energy Control Procedures

OSHA requires that procedures for the control of potentially hazardous energy be developed, documented and be used. Procedures need to be developed for each machine or type of equipment, except when all of the following conditions are met

  • There is no danger to people from the machine or equipment having a potential for stored or residual energy, or for the reaccumulation of stored energy after shut down.
  • The machine or equipment has a single energy source which can be readily identified and isolated.
  • The isolation and locking out of that energy source will completely de-energize and deactivate the machine or equipment.
  • The machine or equipment is isolated from the energy source and locked out during servicing or maintenance.
  • A single lockout device will achieve a locked-out condition.
  • The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance.
  • The servicing or maintenance does not create hazards for other employees.
  • The employer, in utilizing this exception, has had no accidents in the past involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance.

Sample Minimal Lockout Procedure

Lockout Procedure for __________________________________
(Enter the name of the company for single procedure that covers all equipment in a facility, or identify the specific equipment this procedure applies to.)

A. Purpose

This procedure establishes the minimum requirements for the lockout of energy isolating devices whenever maintenance or servicing is done on machines or equipment. It shall be used to ensure that the machine or equipment is stopped, isolated from all potentially hazardous energy sources and locked out before employees perform any servicing or maintenance where the unexpected energization or start-up of the machine or equipment or release of stored energy could cause injury.

B. Compliance With This Program

All employees are required to comply with the restrictions and limitations imposed upon them during the use of lockout. The authorized employees are required to perform the lockout in accordance with this procedure. All employees, upon observing a machine or piece of equipment which is locked out to perform servicing or maintenance shall not attempt to start, energize, or use that machine or equipment.

________________________________________________
(Describe the type of compliance enforcement that will be taken for a violation of the above.)

C. Sequence of Lockout

(1) Notify all affected employees that servicing or maintenance is required on a machine or equipment and that the machine or equipment must be shut down and locked out to perform the servicing or maintenance.

Name(s), Job Titles, and Notification of affected employees

Name

Job Title

How to notify

 

 

 

 

 

 

 

 

 

 

 

 

(2) The authorized employee shall refer to the company procedure to identify the type and magnitude of the energy that the machine or equipment utilizes, shall understand the hazards of the energy, and shall know the methods to control the energy.

Type of Energy

Magnitude

Energy Control Method

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(3) If the machine or equipment is operating, shut it down by the normal stopping procedure (depress the stop button, open switch, close valve, etc.).

Type(s) of Operating Controls

Control Location(s)

 

 

 

 

 

 

(4) De-activate the energy isolating device(s) so that the machine or equipment is isolated from the energy source(s).

Types of energy isolating devices

Locations

 

 

 

 

 

 

(5) Lock out the energy isolating device(s) with assigned individual lock(s).

(6) Stored or residual energy (such as that in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc.) must be dissipated or restrained by methods such as grounding, repositioning, blocking, bleeding down, etc.

Types of Stored Energy

Method(s) Used To Dissipate or Restrain

 

 

 

 

 

 

(7) Ensure that the equipment is disconnected from the energy source(s) by first checking that no personnel are exposed, then verify the isolation of the equipment by operating the push button or other normal operating control(s) or by testing to make certain the equipment will not operate.

Caution: Return operating control(s) to neutral or "off" position after verifying the isolation of the equipment.

___________________________________________________________
(Describe the method of verifying the isolation of the equipment.)

(8) The machine or equipment is now locked out.

Restoring Equipment to Service. When the servicing or maintenance is completed and the machine or equipment is ready to return to normal operating condition, the following steps shall be taken.

(1) Check the machine or equipment and the immediate area around the machine to ensure that nonessential items have been removed and that the machine or equipment components are operationally intact.

(2) Check the work area to ensure that all employees have been safely positioned or removed from the area.

(3) Verify that the controls are in neutral.

(4) Remove the lockout devices and reenergize the machine or equipment.

Note: The removal of some forms of blocking may require reenergization of of the machine before safe removal.

(5) Notify affected employees that the servicing or maintenance is completed and the machine or equipment is ready for use.

Lockout/Tagout Procedures - Labels, Signs and Tags

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Free Best Practice Guide to Lockout/Tagout

A complete reference to LOTO Electrical Safety

Lockout/Tagout Procedures - OSHA Standard Interpretations

To help understand when a lockout procedure is needed, and what the lockout procedure needs to include, OSHA has provided answers to questions asked about lockout requirements. The following are summaries of two of those questions and answers:

Question: We operate several large punch presses in our metal fabrication plant that use several kinds of dies. On occasion our maintenance personnel stand inside the machine guard to look for malfunctions of the dies. Our personnel must be in close proximity to the dies as they come together in order to see the minute imperfections which cause malfunctions. Once a problem is identified, our personnel leave the area and lock the machine out by following machine specific lockout procedures. We cannot properly troubleshoot some of our dies without the machine running and our personnel standing inside of the rear guard. Does 29 CFR 1910.147 allow this practice?

Answer: While it is not possible to conclusively determine the answer to your question without observing the particular pieces of equipment and considering the manner in which they are situated and used, the practices you describe would most likely not be in compliance with 29 CFR 1910.147.

The task you describe involves an employee observing whether the equipment is operating properly. This activity would be considered inspecting the equipment and, therefore, is considered Servicing and/or maintenance as defined in 1910.147(b).

Although LOTO applies to servicing and maintenance, minor adjustments which occur during normal production operations may be exempt from the LOTO under the minor servicing exception. The minor servicing exception applies if the activity is routine, repetitive, and integral to the use of the equipment for production purposes, provided that the work is performed using alternative measures which provide effective employee protection.

If, in your scenario, the minor servicing exception were to apply, you would need to employ alternative safeguarding measures. Such alternative safeguarding measures may include devices such as, but not limited to, two-hand trip or control devices, restraint devices that prevent the employee from entering the zone of danger, video cameras that would allow remote observation of the dies, and plexiglass barriers that allow for close inspection of the operation, yet prevent introduction of the employee's body into the machine hazard area. It must be emphasized that every employee performing these inspection tasks must be protected from exposure to hazardous energy.

If the inspection/troubleshooting activity you describe does not constitute minor servicing during normal production operations, the LOTO standard also recognizes that there are circumstances under which it is absolutely necessary to test and position the machine while energized during servicing and maintenance. (1910.147(f)(1)) However, the provisions also require that employees be removed from the area when the energization and testing and/or positioning occurs. In the event that it is impossible to remove employees from the machine area and still conduct the type of inspection that must be performed, you must provide alternative employee protection through the use of the safeguarding measures previously discussed.

Question: Is an interlock required on the side door of a trash compactor, if the side access door is located 55 inches from ground level, and the door is closed and latched while the compactor is cycling?

Answer: If an employee may be exposed to machine hazards while the machine operates, the hazardous areas of the machine must be guarded.

While it is not possible to conclusively determine the answer to your question without observing the trash compactor and considering the manner in which it is situated and used, it is likely that employees would be exposed to moving parts associated with the trash compactor during the course of their employment. As such, OSHA's machine guarding standard (29 CFR 1910.212) likely would require guarding to prevent employee exposure to the hazards.

While properly designed, constructed, and maintained interlocks generally provide effective machine guarding, 1910.212 does not require the use of interlocks or any other specific guarding methods. The standard describes several acceptable methods for guarding machine hazards, but the standard is performance-oriented, and an employer can comply with the standard by using any method(s) of guarding that provides effective employee protection against the hazard. In the scenario that you described, access to the trash compactor's point-of-operation is covered by a latched, solid door. If the door effectively prevents employee access to the point-of-operation or other machine hazards, the door would be considered effective guarding. However, since barrier guards must be affixed such that they cannot be easily defeated, simply latching the door in a closed position would not be sufficient. Thus, the door would need to be secured such that it could not be easily circumvented.

The information presented in this document was obtained from sources that we deem reliable; Graphic Products does not guarantee accuracy or completeness. Graphic Products, Inc. makes no representations or warranties of any kind, express or implied. Users of this document should consult municipal, state, and federal code and/or verify all information with the appropriate regulatory agency.

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