SM

Lockout-Tagout

Training

SM

Agenda

• Why is Lockout/Tagout (LOTO) important?

• How does LOTO apply to contractors?

• What is required for compliance?

• How to establish an energy control program?

SM

Why is LOTO important?

SM

Risk Mitigation

Financial

Employee Safety Legal

Risk

Mitigation

SM

Employee Safety

• Approximately 3 million workers in the US service equipment and face the greatest risk of injury if Lockout/Tagout is not properly implemented

• Lockout/Tagout prevents an estimated 120 fatalities and 50,000 injuries each year in the US.

• Workers injured from exposure to hazardous energy lose an average of 24 workdays for recuperation

Source: http://www.osha.gov/SLTC/controlhazardousenergy/index.html

SM

Legal Risk

• Created under the Occupational Safety and Health Act of 1970

• Only government regulatory agency for workplace safety

• Instructs, conducts inspections and enforces workplace safety

• Does not apply to government facilities

OSHA General Duty Clause States:“Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”

SM

State Plans

• Twenty-four states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans

• Job safety and health standards must be "at least as effective as" comparable federal standards.

• Most States adopt standards identical to federal ones -- States have the option to promulgate standards covering hazards not addressed by federal standards.

SM

Legal Risk

OSHA Standards• Required by law for employers to follow• Requirements in General Terms• Lots of details but also rely on consensus industry standards for guidelines

NFPA 70E – 2009 (Originated 1976)• Details – safe installation, maintenance and work practices, signs, PPE

(Personal Protective Equipment), shock hazard and AF analysis…• Only applies to electrical energy (Electrically Safe Working Condition)

FINAL RULE 72:7135-7221 in Aug 2007:“The Occupational Safety and Health Administration (OSHA) is revising the general industry electrical installation standard found in Subpart S of 29 CFR Part 1910. The Agency has determined that electrical hazards in the workplace pose a significant risk of injury or death to employees, and that the requirements in the revised standard, which draw heavily from the 2000 edition of the National Fire Protection Association's (NFPA) Electrical Safety Requirements for Employee Workplaces (NFPA 70E), and the 2002 edition of the National Electrical Code (NEC) , are reasonably necessary to provide protection from these hazards.

SM

Legal Risk

• Adopted in 1989• Applies to general industry

employment• Covers about 39 million workers• Established minimum performance

requirements for the control of hazardous energy

• Covers the servicing and maintenance of machines and equipment in which the unexpected start-up or the release of stored energy could cause injury

• Applies to all types of energy: mechanical, hydraulic, electrical, gas, pneumatic, water, chemical, thermal, etc…

OSHA Standard 29 CFR 1910.147:

SM

Legal Risk

“covers electrical safety-related work practices and procedures for employees who work on or near exposed energized electrical conductors or circuit parts in workplaces that are included in the scope of this standard”

“Intended to provide for employee safety relative to electrical hazards in the workplace”

NFPA 70E – Chapter 1 Article 110 States:

Source: NFPA Regulations – Chapter 1, Article 110, 2009

SM

Top OSHA Violations

SIC Code ‘D’ = Manufacturing

SM

Financial Risk

Downtime

• Personnel

• Equipment

Legal Action

• Liability and Injury

• Cost of outside counsel

Fines and Penalties:

• LOTO is #3 most cited by OSHA

• Fiscal Year 2006 38,579 federal OSHA site inspections

58,058 state OSHA site inspections

3,659 violations for LOTO totaling about $6MSource: Occupational Hazards, February 2008

SM

Financial Risk

SM

Risk Mitigation

Conclusion:

“The costs in terms of human suffering, lost productivity, worker’s compensation claims and lawsuits can far outweigh the investment in a comprehensive program.”

Source: Occupational Health&Safety Volume 76, Number 10

SM

How does LOTO apply to

contractors?

SM

Lockout/Tagout for Construction

SM

• 1926.417 is very brief

• 1926.21 mandates training to avoid unsafe conditions

• 1910.147 provides LOTO best practices even though it does not

directly apply to Construction Industry.

• 1910.333 (Selection and use of work practices) provides additional

best practices for safely dealing with electrical energy.

• OSHA General Duty Clause

• When do you fall under 1910 versus 1926?

In the end, proper Lockout/Tagout is for your safety!

Lockout/Tagout

SM

What is required for LOTO

compliance?

SM

Elements of a Lockout/Tagout program

Procedures

Training

Device requirements

Inspections

SM

Procedures

OSHA 1910.147(c)(4)(i)“Procedures shall be developed, documented and utilized

for the control of potentially hazardous energy when employees are engaged in the activities covered by this section”

NFPA 70E 120.2 (F) / Ch. 5-4“The employer shall maintain a copy of the procedures

required by this section and shall make procedures available to all employees”

SM

Procedures

Standards/Codes: OSHA 1910.147(c)(4); NFPA 70E - Article 120.2 (D) & (F), and Annex G

Procedures shall be developed, documented and utilized for the control of potentially hazardous energy:

– Steps to de-energize and re-energize

– Lockout/Tagout devices to utilize

– Drawings/diagrams (equipment specific)

– What employees are exposed to hazards?

– Who is qualified to perform LOTO?

– Who is in charge of the LOTO program?

SM

Procedures

Steps for equipment shutdown

1. Prepare for and announce shutdown

2. Shutdown equipment

3. Disconnect energy sources / test for isolation

4. Lockout and/or Tagout

5. Release stored energy

6. Verify isolation

SM

Procedures

Steps for equipment startup

1. Verify equipment operationally intact - Clear all personnel and tools

2. Ensure employees are safely positioned

3. Remove lockout/tagout devices from each energy-isolating device

4. Notify all affected employees of Lockout/Tagoutremoval and that work has been completed

5. Start equipment

SM

Training

OSHA 1910.147(c)(7)(i)“The employer shall provide training to ensure that the purpose and

function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees”

NFPA 70E 120.2 (B) (2)“Each employer shall provide training as required to ensure

employees’ understanding of the lockout/tagout procedure content and their duty in executing such procedures”

SM

Training

Authorized employees – person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment

Affected employees – employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under Lockout or Tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed

SM

Training

Authorized employees: Recognition of applicable

hazardous energy sources

Type and magnitude of energy available in the workplace

Methods and means necessary for energy isolation and control

Ways to verify that the energy isolation is effective

SM

Training

Affected employees:

Instructed in the purpose and use of energy control procedure

Should never attempt to restart or re-energize machines or equipment which are locked out or tagged out

Respect use of warning tags

SM

When Should a Company Retrain?

New employees, or change in employee responsibilities

New equipment, or change in machines, equipment or processes that present a new hazard or change to energy control procedures

Deviations from, or inadequacies in, the employee’s knowledge or use of the energy control procedure

SM

Device Requirements

OSHA 1910.147(c)(7)(i)“Lockout device – a device that utilizes a positive means such as

a lock, either key or combination type, to hold an energy isolating device in a safe position and prevent the energizing of a machine or equipment”

NFPA 70E 120.2 (E) (2)“Each employer shall supply, and employees shall use,

lockout/tagout devices and equipment necessary to execute the requirements of 120.3(E). Locks and tags used for control of exposure to electrical energy hazards shall be unique, shall be readily identifiable as lockout/tagout devices, and shall be used for no other purpose.”

SM

Device Requirements

Lockouts must be:

Used only to control energy Durable enough for use in their environment Standardized by either color, shape or size Substantial – withstand all but excessive

force Identify the employee applying the device

SM

Device Requirements

Tags must be:

Durable enough for use in their environment

Substantial – enough to resist accidental or inadvertent removal

Standardized by either color, shape or size

Identify the employee responsible for the Tagout

Non-reusable attachment device & attachable by hand

Withstand 50 lbs of force

SM

Inspection

OSHA 1910.147(c)(6)(i)“The employer shall conduct a periodic inspection of the energy

control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.”

NFPA 70E 120.2 (C) (3)“An audit shall be conducted at least annually by a qualified person

and shall cover at least one Lockout/Tagout in progress and the procedure details. The audit shall be designed to correct deficiencies in the procedure or in employee understanding.”

SM

Inspection

At least annually

Performed by authorized employee, other than the one(s) using the energy control procedure

Cover Lockout/Tagout in progress

Between inspector and authorized/affected employees• Lockout – review employees responsibilities under the

energy control procedure inspected

• Tagout – review employee responsibilities and Tagoutlimitations

Document inspection

Correct any deviations or inadequacies identified

SM

Outside Personnel

• Relationship between Host & Contractors

• OSHA 1910.147:– “On-site employer and outside employer shall

inform each other of their respective lockout or tagout procedures”.

– “On-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer’s energy control program”.

• NFPA 70E 110.5:– Host employer must inform outside personnel of

known hazards and information about installation.

– Contract employer must ensure that his/her employees are trained in the hazards and follow host employer safety rules.

SM

Group Lockout/Tagout

OSHA 1910.147(f)(3)(i)“When servicing or maintenance is performed by a crew, craft,

department or other group, they shall utilize a procedure which affords the employees a level of protection equivalentto that provided by the implementation of a personal lockout or tagout device”

ONE authorized employee is responsible for overall procedure in the crew.

If multiple crews are involved, there must still be an overall authorized employee responsible.

Group Lockout devices such as Group Lockboxes and/or hasps must be used.

SM

Shift or Personnel Changes

• “Ensure continuity of lockout or tagout protection”

• Employee from incoming shift MUST apply his/her lockout device before employee from outgoing shift removes his/her device.

• Communicate about the work that has been done

SM

Unavailable Employee

• If authorized employee is not available to remove his device, then the employer may remove it IF:– Employer has procedures and training for such

removal in energy control program– Verification that authorized employee is not at

the facility– Making all reasonable efforts to contact

authorized employee to inform him/her that lockout device has been removed

– Ensuring that authorized employee is aware that his device was removed before resuming work at that facility

SM

How to establish an energy

control program?

SM

The whole process

SM

Conduct a hazard assessment by

identifying all equipment that is used, serviced, maintained or stored

1. Assessment

SM

Determine Lockout/Tagout requirements for all equipment, identifying and documenting all energy sources – and create machine-specific procedures containing:

Type of Hazard

Location on the equipment

Proper isolation and lockout device/procedure

How to dissipate the stored energy

How to verify the isolation

After this step, you should have an energy control program for your facility and machine-specific procedures

2. Procedures

SMSM

Circuit Breakers Electric Plug Toggle Switch Rocker Switch Cable Lockout

Pneumatic Ball valve Gate Valve Group Lock Box Tags

LOTO Stations LOTO Kits Hasps Padlocks Other

3. Devices

SM

A. Train all employees in facility Authorized employees:

• Recognition of applicable hazardous energy sources

• Type and magnitude of energy available in the workplace

• Methods and means necessary for energy isolation and control

• Ways to verify that the energy isolation is effective

Affected and Other employees:• Instruction in the purpose and use of energy

control procedure• Should never attempt to restart or re-energize

machines or equipment which are locked out or tagged out

• Respect use of warning tags

B. Document the training

4. Training

SM

Processes need to be put in place to maintain the comprehensive program for the following:

Periodic Inspections must take place at least annually to identify and correct any deviations or inadequacies.

Retraining must take place anytime there is a change in responsibilities, equipment or procedures along with new employees

5. Processes

SM

In conclusion…

SM

Key Take-Aways for LOTO

1. Only work on equipment “hot” or “live” if it absolutely unavoidable

2. Lockout over Tagout

3. Facility specific and machine specific

4. Don’t forget about secondary energy sources or stored energy

5. Use annual inspections, regular training (annually suggested), and discipline to avoid complacency

6. Lockout/Tagout is only one part of a complete and effective safety program (safety ID, PPE, etc.)

SM

40 Words for Safety

Plan Every Job

Anticipate Unexpected Events

Identify The Hazard

Minimize the Hazard

Use Procedures as Tools

Use the Correct Tools for the Job Task

Use Personal Protective Equipment

Isolate the Equipment

Assess People’s Abilities

Protect the Person

Audit these Principles

SM

References

OSHA 1910 & 1926 NFPA 70E (2009) NEC 2008 www.osha.gov www.nfpa.org Your company Lockout/Tagout procedure