SAFETY SOLUTIONS: Is Your Lockout & Tagout Program Working?

In 2011, failure of employers to properly ensure that their employees are following OSHAŐs 1910.147 Lockout & Tagout standards is still on the top ten items for OSHA citations. As a matter of fact, two of these citations are for failure to conduct the periodic audit at least annually and with each employee and failure to have machine/equipment specific lockout and tagout procedures.

Are you in compliance with these OSHA standards? As a business owner, do you know what these standards require?

It is 2011 and it is not the small mom and pop companies that fail to have these mandatory programs in place. As a matter of record, the majority of large companies do not have a good program in place to protect their workers. Some large companies state they did not want to waste the money to put this mandatory program in place. Perhaps after reading this OSHA document, employers will understand the OSHA regulation and their responsibility to employees:

WASHINGTON -- The U.S. Department of LaborŐs Occupational Safety and Health Administration (OSHA) today proposed $2.78 million in penalties against Ohiobased Cintas Corp. following an inspection into the March 2007 employee death at the Cintas laundry facility in Tulsa, Oklahoma. The employee was killed when he fell into an operating industrial dryer while clearing a jam of wet laundry on a conveyor that carries the laundry from the washer into the dryer. Cintas is the largest uniform supplier in North America, with more than 400 facilities employing more than 34,000 people. The facility in Tulsa has 160 employees.

ŇPlant management at the Cintas Tulsa laundry facility ignored safety and health rules that could have prevented the death of this employee,Ó said Assistant Secretary of Labor for OSHA Edwin G. Foulke Jr. Forty-two willful, instance-by-instance citations allege violations of the OSHA lockout/tagout standard for the failures to shut down and to lock out power to the equipment before clearing jams, and to train four employees responsible to clear jams that lockout/tagout applies and how to perform the operations. One repeat citation alleges the failure to protect employees from being struck or pinned by the conveyor. Three serious citations allege the failures to protect employees from falls, to have a qualified person inspect the lockout/tagout procedures and to certify the procedures as required.

In a separate case, OSHA issued five repeat and two serious citations with penalties totaling $117,500 for violations of the lockout/tagout and machine guarding standards found at the Cintas Columbus, Ohio, facility. OSHA also has opened investigations in Arkansas and Alabama. Washington, an OSHA State Plan state, has issued four citations with proposed fines totalling $13,650, alleging violations for similar hazards at the Yakima Cintas facility. The Control of Hazardous Energy Source Standard (29 CFR l9lO.l47), which is more commonly known as the Lockout/Tagout Standard, is a Federal Occupational Safety and Health Administration (OSHA) program, It is designed to prevent the unexpected start-up, or energizing, of machinery and equipment during service and maintenance operations which could cause injury to employees. It is also designed to prevent the release of stored energy which could cause injury to employees. Industry has been obligated to comply with the Lockout/Tagout Standard since January 3, l990.

The lockout standard applies if:

• The employee is required to remove or bypass a guard or other safety device during service and maintenance.
• An associated danger zone exists during a machine operating cycle.
• The employee is required to place any body part into an area of the machinery or equipment where work is actually being performed upon the material being processed.
• Minor tool changes, adjustments, and other minor service activities, which take place during normal production, are not included in the Lockout/Tagout

1. routine, repetitive, and integral to the use of the equipment, and that they are performed using alternative measures which provide effective protection for the employee.

Most people immediately think of electricity as a potentially hazardous energy source. There are other sources of energy, though, that can be just as hazardous. These energy sources include thermal, chemical, pneumatic, hydraulic, mechanical and gravity, It is important to remember that all sources of energy that have the potential to unexpectedly start-up, energize or release must be identified and locked, blocked or released before servicing or maintenance is performed.

Written Lockout/Tagout Program

In order to comply, a company must prepare a written Lockout/Tagout Program which includes the scope, purpose, authorization, rules and techniques to be utilized in the control of hazardous energy. Training must also be provided to all employees who are affected by the Lockout/Tagout procedures.

The written program must have:

• A specific statement as to the intended use of the program. Specific steps for shutting down, isolating, and blocking machinery and equipment in order to control hazardous energy.
• Specific procedures for the placement and removal of lockout/tagout devices as well as the method of identifying an individual's locks or tags.
• Requirements for verifying the effectiveness of the lockout/tagout device by testing procedures for machinery and equipment.
• A detailed training program for employees who perform the service and maintenance and for employees who are indirectly affected by those operations.
• Descriptions of company lockout/tagout policies regarding multiple lockout/ tagouts, outside personnel, shift changes, and training of employees.

The basic equipment needed for a lockout/tagout procedure are locks and/or tags. Locks are to be utilized whenever possible. Both locks and tags must clearly indicate the identity of the employee who applied the device. This provides positive identification as to who is servicing the machinery and equipment. The identification will also indicate who may not have finished working in a multiple lockout/tagout situation. The locks and tags must be durable enough to withstand the environment in which they will be used. Information on the locks and tags must remain legible, Locks must be substantial enough to prevent removal without the use of excessive force.

Tags must be substantial enough to prevent accidental or inadvertent removal. Both locks and tags are to be standardized by either color, shape or size. Tags must have a standard print and format, If an energy isolating device is not capable of being locked out, a tag is to be used. An energy isolating device is simply a mechanical device that physically prevents the transmission or release of energy. All machinery and equipment must be designed to accept a lockout device when major replacements, repairs, renovations, modifications of machinery or equipment are performed, or whenever new machinery is installed.

An audit should be conducted on all machines and equipment to identify all potentially dangerous energy sources and all energy isolating devices. By doing this, employers will be able to establish all appropriate lockout/tagout procedures.

Should you need additional information on this mandatory regulatory requirement, please feel free to contact me or visit my website at www.podojilconsulting.com. OSHA has many publications, including specific topics for small businesses that are available or can be ordered online. Additional resources of information on safety-related topics and programs include:

• National Institute for Occupational Safety & Health - www.cdc.gov/niosh
• Canadian Center for Occupational Health & Safety - www.ccohs.ca
• National Safety Council - www.nsc.org
• American Society of Safety Engineers - www.asse.org
• Podojil & Associates (www.podojilconsulting.com) also has free safety topics, training materials, monthly toolbox talks, safety checklists and PowerPoint programs that you can download free.

For more information, click on the author biography at the top of the page.