In last month’s column (“Lockout/Tagout: The Devil is in the Details,” Machine Design, March 17, 2011) discussed some details that regularly trip up companies applying 29 CFR 1910.147, OSHA’s “Control of Hazardous Energy (Lockout/Tagout).” Some of those details come from pretty basic questions like the “whens” and “hows” of lockout/tagout (LO/TO) procedures.

OSHA estimates that 2% of workplace deaths, about 122 fatalities, could be avoided in establishments affected by the standard if everyone complied with the rule. In addition, proper LO/TO could prevent 28,400 lost-workday injuries and 31,900 nonlost-workday injuries yearly.

LO/TO techniques protect workers from the unexpected release of hazardous energy, so workers do not have to apply LO/TO if their service or maintenance tasks don’t have the potential to expose them to this kind of hazard. For instance, if a technician
servicing or maintaining electrical equipment keeps control over the cords and plugs that could energize the unit, he doesn’t have to do LO/TO.

LO/TO is required anytime a worker might be exposed to the hazards associated with a machine operating cycle. This includes removing or bypassing guards or other safety devices, touching the point of operation with any body part, or placing any body part into an area that would be dangerous if the machine started up.

In addition, workers must do LO/TO for servicing tasks that don’t happen during normal production operations if it is possible they could be injured if the equipment unexpectedly turned on. This most commonly applies to equipment setup or adjustment. LO/TO procedures are also required when workers service equipment with the power off to prevent the unexpected release of hazardous energy.

Before LO/TO devices are removed and energy is restored to the equipment, workers must ensure equipment components are operationally intact, notify affected employees — usually equipment operators — that the worker who applied energy-isolating and LO/TO devices is now removing them. The specifics of these requirements are covered in sections 6(e) and 6(f) of 29 CFR 1910.147.

Companies need energy-control procedures that outline the scope, purpose, authorization, rules, and techniques that will be used to enforce compliance. Such procedures need to include step-by-step instructions and detail how they will be administered.

They should clearly state when and how the procedure will be used. They also need to cover the steps workers are to take preshutdown and during shutdown to isolate equipment from energy sources, safely release potentially hazardous energy, lockout energy-isolating devices, and verify the isolation of the equipment before starting maintenance. They should include the steps for safe placement, removal, and transfer of lock devices and a description of who is responsible for the devices.

OSHA recognizes that some servicing operations must take place with the power on. One example is the troubleshooting of machine problems and ensuring problems have been corrected. And some machines, like printing presses, must be running during setup. OSHA requires the employer provide effective protection for employees performing such operations.

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