More Than Padlocks

In February 2008 OSHA issued a new lockout/tagout directive for its field inspectors – the first update since 1990. This directive instructs OSHA enforcement personnel in two areas: the agency's interpretations of the lockout/tagout standard and the procedures for enforcing them. While the directive is not a new standard or regulation, it provides clarification and advice to the OSHA inspectors. The directive also serves as a guide for organizations seeking to fully understand and comply with the OSHA CFR 1910.147 Control of Hazardous Energy (lockout/tagout) standard.

The new directive emphasizes that OSHA compliance and safety officers are to evaluate the employer's training program along with a company's lockout/tagout processes, procedures, and equipment. Additionally, the new directive outlines requirements for lockout of power circuits and identifies when machine guarding is an acceptable alternative. Companies having comprehensive lockout/tagout procedures in place – with policies for regular assessment of the program as well as employee training – will be in the best position to comply with the standard and avoid OSHA fines.

POWER CIRCUIT VS. CONTROL CIRCUIT

Lockout/tagout regulations require the most complete and safe isolation of hazardous energy sources. Because OSHA considers lockout/tagout of the power circuit significantly safer and more reliable than control circuit protective measures, the new lockout/tagout directive clarifies that control circuits are NOT considered energy isolating devices.

Control circuits – which include push buttons, selector switches, safety interlocks, programmable logic controllers, on/off key switches, etc. – are more prone to service failures due to component failure, program errors, magnetic field interference, electrical surges, lack of maintenance, etc.

The standard defines an "energy isolating device" as a mechanical device that, when utilized or activated, physically prevents the transmission or release of energy. These can include a manually operated electrical circuit breaker, a disconnect switch, or a manually operated switch by which the conductors of a circuit can be disconnected.

MACHINE GUARDING: A LOCKOUT / TAGOUT ALTERNATIVE

In some cases, OSHA recognizes it may not be possible or practical to completely isolate all hazardous energy. In these cases, the focus turns to preventing employee exposure to the energy. The new OSHA directive discusses when machine guarding methods, such as barrier guards or enclosure guards, can be used as alternatives to lockout/tagout procedures during servicing and/or maintenance activities.

Appropriate OSHA-approved machine guarding methods must meet two criteria:
? They must be formal guards or barriers, clearly identified and understood as such, not makeshift or temporary barriers; and
? The barriers must be clear and obstructive enough to prevent accidental passage through the barrier.

EMPLOYEE TRAINING: CLOSING THE LOOP

The best lockout/tagout policies and procedures won't help avoid accidents if they aren't clearly understood and followed. For this reason, the new OSHA directive specifically focuses on the employer's training program. OSHA inspectors are instructed to verify specific levels of training and understanding of procedures for authorized, affected, and other employees.

Authorized employees are defined as those who must lock out or tag out machines and/or equipment in order to perform service or maintenance. They must recognize and understand:
? All applicable hazardous energy sources;
? The type and magnitude of energy found in the work-place;
? The means and methods of isolating and/or controlling energy, including specific methods for tagout activities;
? How to verify that effective energy control has bee achieved and the specific purpose of each lockout/tagout procedure used.

Affected employees must be instructed in the purpose and use of the energy control procedures. OSHA defines these employees as those whose job requires them to operate or use a machine or equipment that is being or will be serviced or maintained under a lockout/tagout procedure, or whose job requires them to work in the area.

Other employees who work in the area must be instructed about the lockout/tagout procedure and the prohibition against attempting to restart or reenergize machines or equipment that are locked out or tagged out. While these employees are not directly responsible for service or operation of the machines, any employee who does not understand the importance of the lockout/tagout procedures represents the risk of dismantling them – unwittingly starting up a machine or removing a barrier during a service operation, for example.

THE FOUR-STEP PLAN TO AN EFFECTIVE ENERGY CONTROL PROGRAM

Many companies assume that if they've purchased all the right protective equipment – lockout/tagout padlocks, signs, barriers, etc. – that the rest will fall into place. The truth is that the lockout/tagout tools and warning devices, while important, are only one part of the four steps to an effective OSHA-compliant lockout/tagout program:

Step 1. Create energy control policies and procedures: To complete this step, one must first define the difference between a lockout/tagout policy and specific lockout/tagout procedures. A company's lockout/tagout policy is the documentation of the overall method by which lockout/tagout process, procedures, enforcement, training, evaluation/audits, and updates will be performed.

Procedures outline the specific activities to be performed in each lockout/tagout activity. To meet the OSHA standard, lockout/tagout procedures must meet the following criteria.
? All procedures must be documented and identify the equipment covered.
? Each piece of equipment to be locked out must have a specific procedure.
? Each procedure must include specific steps for shutting down, isolating, blocking, and securing equipment to control hazardous energy.
? Each procedure must include specific steps for the place-ment, removal and transfer of lockout/tagout devices.
? The employer must conduct and certify periodic inspections at least yearly.

Companies can meet the OSHA requirements for Step One in several ways, including on-site assessments from outside contractors, lockout/tagout graphical procedure-writing software programs, and pre-printed tags or labels. The method you choose depends on the size of your plant, the number of machines involved, and the number of employees affected.

Step 2. Identify all energy control points: OSHA requires identification to include the energy magnitude and purpose unless it is evident. Additionally, ANSI standards state that all energy-isolating devices be clearly labeled. Identification should include the machine, equipment, or process involved.

The tools and devices for identification of energy control points include tags, signs, and labels. These can be pre-printed stock messages designed specifically to comply with OSHA standards, or custom-printed messages created to meet your specific needs as well as regulatory requirements.

Using an industrial label printer with appropriate label-creation software allows companies to create machine-specific signs, labels, and tags at the point of need – anywhere, anytime – without waiting for a sign order to arrive. A high-quality printing system enables you to meet your lockout/tagout needs and create signs for Hazardous Communications (Right to Know), Arc Flash, and general equipment identification.

Step 3. Equip employees with the proper lockout tools and warning devices: Typical lockout devices include cable and chain lockouts, valve lockouts, padlocks, electrical lockouts and many others, determined by the machine and the type of energy that must be controlled. OSHA-compliant lockout devices must identify the individual who applied the lock and remain under that person's exclusive control.

The locks must be standardized by size, shape, or color, and be distinguishable from locks used for other purposes. Durability is also a factor, as the locks must be strong enough to prevent removal except by using excessive force.

Step 4. Train employees and promote awareness of safe work practices: The OSHA standard also requires that the employer be able to certify that training has been completed and being kept up to date.

WHAT ABOUT THE BOTTOM LINE?

Lockout/tagout is the most frequently cited OSHA violation for general industry. Citations can cost a company in a big way: fines can run from thousands of dollars to several hundred thousand dollars and more for repeat violations.

Each year, up to 50,000 injuries occur and 120 lives are lost due to lockout/tagout incidents. Consider the personal tragedy, insurance costs, litigation and even damage to equipment, and suddenly lockout/tagout policies and procedures become one of the most cost-effective ways to protect both your employees and your bottom line. Properly followed lockout/tagout procedures save time on routine maintenance operations, increase productivity and help your company meet its lean manufacturing protocols.

Tom Campbell is the regulatory compliance market manager for Brady Corporation, P.O. Box 571, Milwaukee, WI 53201-0571, 800-541-1686, Fax: 800-292-2289,
www.bradyid.com/lockouttagout, www.osha.gov.