#oshaguidelines

Adhering to OSHA regulations is essential when implementing Lockout Tagout procedures during machine maintenance or servicing. In previous blogs, we have explored various OSHA guidelines in depth. In this blog, the focus shifts to a critical concept within those standards - “capable of being locked out” - and its implications for equipment safety and compliance An energy-isolating device is considered CAPABLE OF BEING LOCKED out if:

·  It is designed with a hasp or other means of attachment.

·  It has a locking mechanism.

· If a lockout can be achieved without the need to dismantle, rebuild, or replace the energy isolating device.

Energized: A machine is said to be energized if it is connected to an energy source. Or if it contains any stored energy- chemicals, gases, liquids; Energy from the movement of springs; Pressurized and moving gases, etc.

Under section (B) of (c)(5)(ii) of the OSHA Standard 1910.147, requires that Lockout Tagout Devices must be standardized in either colour, shape, size, print or format. The requirement of the standardized devices is meant to ensure that they are readily identifiable, unique, and distinguished from other similar devices found in the workplace. The intent of these provisions is to elevate the importance of Lockout Tagout devices and ensure that all the employees understand their distinct and exclusive purpose - to protect services & maintenance employees from accidental start-up or the release of stored energy. Section (c)(5)(ii)(D) of the standard requires that Lockout Tagout devices identify the employees who apply them. This requirement adds a degree of accountability to the LOTO program. Once the involved employee is identified, he/she can be located when needed. This identification is also essential as it enables the employer to quickly determine the identity of the employee who forgot to remove his lockout Tagout device. Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

According to OSHA Standard 1910.147(c)(5)(ii)(A) - The Lockout Tagout devices must be DURABLE. The durability requirements are intended to ensure that the Lockout Tagout devices will not fail to perform their intended job. The LOTO Devices must be durable enough to resist the harsh environmental conditions - chemicals, abrasion and temperatures, to which they are exposed to for the expected period of time.

Tags and their means of attachment must be constructed and printed, so that the exposure to weather or other environmental conditions does not cause them to become unserviceable or the message on the Tag to become illegible. Using laminated Tags with reinforcing eyelets is generally adequate for the vast majority of work environment.

Tags so constructed, must also be durable enough to withstand the corrosive environment, especially the areas where acid and alkali chemicals are handled and stored.

The OSHA Standard, 1910.147 (c) set forth nine general principles which provide the framework for ensuring the safety of personnel who maintain the machines.

OSHA Standard 1910.147(c)(2) emphasizes on the importance of Full Employee protection by Lockout Tagout.

Generally, the isolation devices should be capable of being locked out in majority of circumstances. But, there can be incidences where a Tagout device is used instead. A Tagout device, without a Lockout, may be used only when energy isolating device, is not capable of being locked out, or when the employer demonstrates that use of the tagout system alone, is substantial enough to be used in place, where the Lockout device is not applicable. It must provide a level of safety equivalent to that obtained by using a Lockout device, and the Tagout device must be attached at the same location, where the Lockout device would have been attached.

In such a situation, it solely becomes the responsibility of the employer to provide ‘full employee protection.’

After January 2, 1990 according to the standard 1910.147 (c)(2)(iii), it has become mandatory for the manufacturers, that in case of modification of machines and equipments, whenever replacement, major repair or installation of new machines are done, the energy isolating devices for such machines or equipment shall be designed to accept a lockout device.

Most of the injuries and fatalities in industries occur while workers perform service and maintenance tasks. The Lockout Tagout Standard set forth in 29 CFR 1910.147 covers the servicing and maintenance of machines and equipment in general industry. Activities such as construction, installation, setting up, inspection, etc. are defined by OSHA as services and maintenance.

These activities include lubrication, cleaning, unjamming, making adjustments or tool changes, are integral to the use of equipment. These are considered service and maintenance if employees are exposed to unexpected energization or startup of the machines or equipment, or release of stored energy could cause injury to employees.

Setting up: Many servicing or maintenance activities require the machine, equipment, or its components to be disassembled or dismantled. These tasks are typically performed with the equipment stopped.

The reassembling of machines and equipment after the servicing and maintenance task has been performed is called setting up.

Lockout consists of placing a disconnect switch, breaker, valve, spring, pneumatic assemble, or other energy-isolating mechanism in the off or safe position. A device is placed over, around, or through the energy-isolating mechanism to lock it in the off or safe position, and only the person attaching it applies a removable lock to the apparatus.

When the machine’s energy sources are locked out, there are specific guidelines that must be followed to make sure that the lockout device cannot be removed, and the system cannot be inadvertently operated. OSHA illustrates certain Lockout Tagout procedures that need to be followed while performing LOTO.

Every company has its drafted Energy Control Procedures/MSP that needs to be implemented systematically. It is the duty of the employer to make sure that the machine is not restarted until the Lockout device is removed.