6-Point Lockout/Tagout Action Plan
Lockout/Tagout procedures need to be implemented when it’s time to repair or service equipment and machinery on a jobsite – so, it can happen frequently. The hazardous energy used to power onsite machines and equipment must be turned off and controlled during servicing. However, there is more to safety precautions than simply powering down a piece of equipment and getting to work. All potential energy sources to the equipment must be stopped, all excess energy emitted from the machines, and all affected workers need to know the machine is unavailable during servicing. This is where implementing Lockout/Tagout procedures and equipment come into play. Here’s 6 actions to take to have a solid Lockout/Tagout program in place.
The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147, addresses the practices and procedures necessary to disable machinery or equipment, thereby preventing the release of hazardous energy while employees perform servicing and maintenance activities.
OSHA estimates that workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation. However, compliance with OSHA’s Lockout/Tagout standard prevents an estimated 120 fatalities and 50,000 injuries each year. Unfortunately, the OSHA Lockout/Tagout standard is often violated and OSHA ranks Lockout/Tagout violations in the Top 5 of all industries.
The reason to implement Lockout/Tagout procedures is to prevent workers from being injured or killed during servicing or maintenance of equipment. Accidentally turning on a machine while it is being serviced can cause grave injury to anyone working on the machine as well as those around it. Potential injuries workers face when servicing equipment that has not been not properly turned off or locked out include: amputation, broken bones, electrocution, burns, or even death.
OSHA offers the following scenarios for potential injuries when equipment is not locked out properly:
- A steam valve is automatically turned on burning workers who are repairing a downstream connection in the piping
- A jammed conveyor system suddenly releases, crushing a worker who is trying to clear the jam
- Internal wiring on a piece of factory equipment electrically shorts, shocking the worker who is repairing the equipment
Specifically, craft workers, electricians, machine operators, and laborers are among the three million workers who service equipment and face the greatest risk of injury.
“Machine-related injuries or fatalities can occur during maintenance and servicing tasks when workers are exposed to an uncontrolled release of energy or during unexpected equipment startup. If machines start up during maintenance, repair, adjusting, or servicing, workers can be caught in the machinery and suffer fractures, crushing injuries, amputations, or death [NIOSH].”
To ensure the safety of workers servicing equipment, the National Institute for Occupational Safety and Health (NIOSH) recommends companies implement Hazardous Energy Control Programs that include Lockout/Tagout procedures and regular employee training on those procedures.
For the sake of safety, the various energy sources supplying power to the machinery that is being repaired or serviced needs to be controlled. The term ‘Lockout’ means the control of this hazardous energy. The energy sources identified as requiring Lockout/Tagout procedures are:
- Other Energy Sources
It is important to note that energy can be stored in equipment even after it has been turned off. Expelling any stored energy is a key component of Lockout/Tagout procedures.
When equipment needs servicing or repair, it is important to follow basic Lockout/Tagout steps. Typically, the Authorized Person will conduct the following tasks and inform the rest of the crew and Affected Persons of the timeline.
- Identify all energy sources to machine or equipment being serviced
- Inform affected employees that Lockout/Tagout will be occurring and have them exit the area
- Shut down equipment normally
- Isolate energy sources for the equipment
- Install the locks and tags on the isolated devices (install on actual power switch when possible)
- Expel any stored energy in equipment by running equipment after it has been disconnected from power source to ensure energy is completely expended
- Conduct repairs or servicing, reinstall all parts, and remove leftover debris
- Remove locks and tags from isolated devices
- Re-energize machinery or equipment
- Notice affected employees it is safe to begin working again
The purpose of Lockout/Tagout at a construction site is to protect workers from injury while equipment is being serviced; this means protecting the workers fixing the machine and the ones working nearby. Therefore, proper procedures require that designated people are responsible for managing the Lockout/Tagout process.
The Authorized Person holds the key—literally. They are in charge of the keys and locks used to lock up the machines and they are the only ones allowed to put locks/tags on before work begins and, more importantly, remove them when work is complete. The Authorized Person starts by identifying, turning off and disconnecting the equipment to be worked on from its power source, discharging any stored energy in the equipment, and locking/tagging the energy-isolating devices before servicing work can begin. They are responsible for notifying all affected employees that Lockout/Tagout has begun and are the only ones who can unlock/untag equipment when it is safe to do so.
The Affected Employees are those whose jobs are interrupted or otherwise affected by the Lockout/Tagout. This usually includes the operator of the machinery being serviced, however, all workers who have to suspend work while the Lockout/Tagout is occurring are affected employees.
The proper use and installation of Lockout/Tagout devices ensures that an energy isolation device is held in a ‘safe’ position. The use of a Lockout/Tagout-specific lock prevents a machine or piece of equipment from becoming energized while it is being serviced. These locks must be durable and visible. The Authorized Person literally places the Lockout/Tagout lock on the equipment and holds the key. Locks are not unlocked until the work is complete, the area has been cleaned, and the equipment is ready to be reenergized.
Tags should always been used with locks; a tag is placed on the equipment with the lock. Tags usually say: “Danger,” “Do Not Operate,” or “Do Not Start.” The tag may also contain a warning about the repair, information about the Authorized Person, and an expected completion date. Tags alone do not physically prevent anyone from accessing the machinery because they can be overridden or overlooked. It is strongly recommended that Lockout/Tagout are used in combination to create the safest environment.
Protect Your Workers With LOTO Best Practices
Of course, the reason to institute a Lockout/Tagout program and set of procedures is to ensure worker safety. Companies need to have a Lockout/Tagout program that is documented, up-to-date, and understood by workers. All workers need to be trained and then retrained regularly. Specifically, new workers and temporary workers—who may be at greatest risk of injury—need to be trained on Lockout/Tagout when they come on board. Reviewing processes and procedures regularly with all employees will reduce injuries and accidents.
LOTO Standards Need To Change With The Times
In our industry, we all work with our hands. But there are pockets of construction where automation and robotics are being utilized more and more; from excavating, grading, and demo-related work, to welding, tying rebar, and other highly repetitive tasks. There is no need to panic just yet that robots are coming for your job, but in certain applications, automation in construction is proving to save time and is definitely beginning to trend upward.
Robotic machinery used in today’s automated jobs is vastly different from traditional machinery and equipment. Some equipment is calibrated on a micro-level and shutdowns can adversely affect these highly sensitive electronic components. In the late 80s, when the existing standards were forged, OSHA had no way of knowing about the level of advancement in robotics. For this reason, the existing Lockout/Tagout (LOTO) standards are up for consideration.
OSHA Standard 29 CFR 1910.147 “regulates the control of exposure to unexpected energization during service and maintenance on machines or equipment.” This standard requires that energy from power sources be controlled by energy isolating devices (EIDs) when being serviced for the safety of workers. However, the current OSHA definition of EID specifically excludes push buttons, selector switches, and other control circuit type devices; equipment that makes up much of the technological advances of today.
OSHA’s 30-year old standard may be getting an upgrade. In May 2019, OSHA issued a Request for Information seeking “information regarding two areas where modernizing the Lockout/Tagout standard might better promote worker safety without additional burdens to employers: control circuit type devices and robotics.” OSHA is considering updating the standard to reflect newer technology as well as the advances in safety. OSHA is looking at how control circuit type devices could be used in the control of hazardous energy and revisiting the Lockout/Tagout standard to consider whether to allow the use of control circuit type devices for some tasks or under certain conditions.
Recently, OSHA sought public comment and input from stakeholders on proposed changes to the current standard. Based on this input, an update to the standard that accommodates the evolving technology of robotics and using control circuit type devices to isolate energy could be in the near future.