“Why Lock-Out, Tag-Out IS Vitally Important” #LOTO #Safety

Caution: Somewhat Graphic Photo – Note: This Photo is the property of Jack Benton, and may not be used without written consent!

Why LOTO is Vitally Important 3

Why LOTO is Vitally Important 

Note: The photo above is not intended for page views or shock value as I don’t believe that those methods truly teach you anything in and of themselves. I don’t know the particulars of the above accident, but I do know that the lack of a proper lock out – tag out (control of hazardous energy) policy and procedure contributed to the accident.

This is always on OSHA’s Top 10 Violations list on a yearly basis, typically coming in at number 2 each year in the total number of times cited. Please use the training information below to keep your employees safe and involved in this process at your workplace.

Remember to AUDIT your procedures more than once per year. LOTO can be a difficult procedure especially when your job or facility has large manufacturing equipment such as a multi-employee operated mile long paper mill versus many single employee operated machines.

Hopefully, the Temp Worker Without LOTO Training who lost his life on the first day of his new job and the LOTO Webinar below, as well as the other resources further down the page will help you to put together an appropriate LOTO policy and procedure for your company.

Ninety minutes into his first day on the first job of his life, Day Davis was called over to help at Palletizer No. 4 at the Bacardi bottling plant in Jacksonville, Fla. What happened next is an all-too-common story for temp workers working in blue-collar industries. Read the investigation: http://www.propublica.org/article/tem..

The Control of Hazardous Energy (Lockout/Tagout) Full Webinar 2016

What is hazardous energy?

Energy sources including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources in machines and equipment can be hazardous to workers. During the servicing and maintenance of machines and equipment, the unexpected startup or release of stored energy can result in serious injury or death to workers.

What are the harmful effects of hazardous energy?

Workers servicing or maintaining machines or equipment may be seriously injured or killed if hazardous energy is not properly controlled. Injuries resulting from the failure to control hazardous energy during maintenance activities can be serious or fatal! Injuries may include electrocution, burns, crushing, cutting, lacerating, amputating, or fracturing body parts, and others.

  • 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 worker who is repairing the equipment.

Craft workers, electricians, machine operators, and laborers are among the 3 million workers who service equipment routinely and face the greatest risk of injury. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation.

What can be done to control hazardous energy?

Failure to control hazardous energy accounts for nearly 10 percent of the serious accidents in many industries. Proper lockout/tagout (LOTO) practices and procedures safeguard workers from hazardous energy releases. OSHA’s Lockout/Tagout Fact Sheet* describes the practices and procedures necessary to disable machinery or equipment to prevent hazardous energy release. The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry outlines measures for controlling different types of hazardous energy. The LOTO standard establishes the employer’s responsibility to protect workers from hazardous energy. Employers are also required to train each worker to ensure that they know, understand, and are able to follow the applicable provisions of the hazardous energy control procedures:

  • Proper lockout/tagout (LOTO) practices and procedures safeguard workers from the release of hazardous energy. The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry, outlines specific action and procedures for addressing and controlling hazardous energy during servicing and maintenance of machines and equipment. Employers are also required to train each worker to ensure that they know, understand, and are able to follow the applicable provisions of the hazardous energy control procedures. Workers must be trained in the purpose and function of the energy control program and have the knowledge and skills required for the safe application, usage and removal of the energy control devices.
  • All employees who work in an area where energy control procedure(s) are utilized need to be instructed in the purpose and use of the energy control procedure(s), especially prohibition against attempting to restart or reenergize machines or other equipment that are locked or tagged out.
  • All employees who are authorized to lockout machines or equipment and perform the service and maintenance operations need to be trained in recognition of applicable hazardous energy sources in the workplace, the type and magnitude of energy found in the workplace, and the means and methods of isolating and/or controlling the energy.
  • Specific procedures and limitations relating to tagout systems where they are allowed.
  • Retraining of all employees to maintain proficiency or introduce new or changed control methods.

OSHA’s Lockout/Tagout Fact Sheet* describes the practices and procedures necessary to disable machinery or equipment to prevent the release of hazardous energy.

The control of hazardous energy is also addressed in a number of other OSHA standards, including Marine Terminals (1917 Subpart C), Safety and Health Regulations for Longshoring (1918 Subpart G), Safety and Health Regulations for Construction; Electrical (1926 Subpart K), Concrete and Masonry Construction (1926 Subpart Q), Electric Power Transmission and Distribution (1926 Subpart V), and General Industry; Electrical (1910 Subpart S), Special Industries (1910 Subpart R), and Electric Power Generation, Transmission and Distribution (1910.269).

Highlights
  • Lockout-Tagout Interactive Training Program. OSHA eTool. Interactive tool to provide the user with an in-depth understanding of the LOTO standard, with three components: Tutorial, Hot Topics, and Case Studies.
  • Construction. OSHA eTool. Helps workers identify and control the hazards, including electrical hazards, that commonly cause the most serious construction injuries.
    • Electrical Incidents. Landing page for Electrical Incidents subpage of the Construction eTool, which identifies electrical hazards and recommends preventive measures.
  • Electric Power Generation, Transmission, and Distribution. OSHA eTool, (January, 2010). Assists workers in identifying and controlling workplace hazards.
Lockout/Tagout Concepts
Lockout/Tagout Program

Example elements of a lockout/tagout (LOTO) program are described in the OSHA standard for the control of hazardous energy (29 CFR 1910.147), along with these additional references.

Other Resources
Training
  • Lockout-Tagout Interactive Training Program. OSHA eTool. Interactive tool to provide the user with an in-depth understanding of the LOTO standard, with three components: Tutorial, Hot Topics, and Case Studies.
    • Case Studies. Presents a series of case studies for review, followed by related questions. Each of the case studies is based on descriptions of LOTO inspections derived from compliance interpretations, court decisions, Review Commission decisions, and inspection files.
  • Small Business Handbook (PDF). OSHA Publication 2209, (2005). Handbook is provided to owners, proprietors and managers of small businesses to assure the safety and health of workers.
  • Lockout/Tagout. National Ag Safety Database (NASD) Research Publications-11. Brief publication providing an overview of lockout/tagout, California laws and regulations, and training materials.
Additional Information
  • Fatality and Catastrophe Investigation Summaries. OSHA. Enables the user to search the text of Accident Investigation Summaries (OSHA-170 form) for words that may be contained in the text of the abstract or accident description.
  • Z244 Committee Information. American Society of Safety Engineers (ASSE).
  • Safety Alert: Control of Hazardous Energy – Lockout/Tagout (LO/TO) Procedures in Shipyard Employment*. OSHA and Shipbuilders Council of America, National Shipbuilding Research Program, and American Shipbuilding Association Alliances (now the Shipbuilding Group Alliance) and the American Industrial Hygiene Association and American Society of Safety Engineers Alliances, (February 2009). Safety Alert Fact Sheet that provides information on how to protect employees from hazardous energy. Also available in Spanish*.
  • Safety Alert: Electrocution and Shock Hazards in Shipyard Employment*. OSHA and Shipbuilders Council of America, National Shipbuilding Research Program, and American Shipbuilding Association Alliances (now the Shipbuilding Group Alliance) and the American Industrial Hygiene Association and American Society of Safety Engineers Alliances, (February 2008). Safety Alert Fact Sheet that provides information on how to protect employees from electrocution and shock hazards. Also available in Spanish*.
Related Safety and Health Topics

“Grain Bin Safety” – “Don’t Get Buried Alive….In An Instant”

Video From ABC TV Series “In An Instant”

Grain Bin Safety Week – 15 Tips to Keep You Safe

1.) Maintain grain quality (e.g. moisture, heat, etc)

2.) Never enter a bin without a “bin entry permit”

3.) Never enter a grain bin unless it is really truly necessary

4.) Never enter a grain bin alone – have an outside observer who can both see and hear you

5.) Most young teens do not have the experience, training or qualifications to help you.

6.) Time is of the essence – if you’re engulfed, it takes only 90 seconds for you to die

7.) The outside observer needs to have a sure quick method to contact emergency responders in an emergency

8.) Always lockout unloading equipment before entering (so they can’t be turned on by mistake)

9.) Always check oxygen (min 19.5%) and toxic/inflammable gas levels (phosphine CO2 dust etc) before entry

10.) Always, always use secure a lifeline (harness/rope/ladder) for everyone inside

11.) Ensure that there’s adequate lighting inside  People---Group-of-Firefighters Nationwide Agribusiness

12.) The lifesaving tip of last resort = cross your arms in front of your chest if you’re sinking – so that you can breathe

13.) Even during the most frantic times, never every risk your or anyone else’s life with a 5-minute shortcut

14.) Have a written plan for training and rescue

15.) The most important safety tip – train-and-practice often

Grain bin safety is such an important task that no one should take lightly. In addition to the tips above we want to share a fantastic contest with you that is going on now. Nominate your local fire department to win an invaluable grain bin rescue training and the rescue tube, brought to you by Nationwide Agribusiness.

Other great resources:

Learn more about our sponsor Nationwide Agribusiness on YouTube http://www.youtube.com/watch?v=p4zOjiKXz6o – and their website.

Download the “Safe Grain Bin Entry” PowerPoint Presentation Below!

Safe Grain Bin Entry

“Donnie’s Accident” – “I Was Too Good To Need My Safety Gear”

Donnie's Accident

On August 12, 2004, I was connecting large electrical generator in preparation for Hurricane Charlie. The meter I was using failed and blew carbon into the gear and created an electrical arc which resulted in an arc blast. The electrical equipment shown in the video is the actual equipment after the explosion when my co-workers were there trying to restore power and make temporary repairs. I ended up with full thickness, 3rd degree burns to both hands and arms along with 2nd and 3rd degree burns to my neck and face. I was in a coma for two months due to numerous complications from infections and medications.

During this time my family endured 4 hurricanes and the possibility of losing me. I am a husband, a father, a son and a brother, not just an electrician. It took almost two years of healing, surgeries and rehabilitation to only be able to return to work to an office job. I can’t use my hands and arms as well as I once could… BUT I’M ALIVE! There are those who have had similar accidents and fared much, much worse. I use my experiences to caution others.

All of this could have been avoided if I had been wearing my personal protection equipment (PPE), which I was fully trained to do and was in my work van. I would have probably only gone to the hospital for a checkup! I am asking you to protect yourself by following your safety procedures. Accidents at work not only affect you; think about the effects on your family, your friends, your finances, your company, your co-workers… your entire world.

Most of these injuries can be prevented by following the safety rules your company probably have in place. Most of these rules were put in place because of accidents like mine. Be safe, wear your PPE; not for fear of fines, penalties or getting fired. Be safe for yourself and for all the people close to you. I got a second chance… You might not!!! !!!

You can read a more in depth account of my accident on the “Full Story” page.

OSHA Arc Flash Safety Information
Understanding “Arc Flash” – Occupational Safety and Health …
https://www.osha.gov/…/arc_flash_han…

Occupational Safety and Health Administration

Employees must follow the requirements of the Arc Flash Hazard label by wearing the proper personal protective equipment (PPE), use of insulated tools and other safety related precautions. This includes not working on or near the circuit unless you are a “qualified” worker.

“NFPA 70E – 2017” – “LOTO & Arc Flash Proposed Changes From Second Draft Meeting “

NFPA-70E-2015

The second draft meeting for NFPA 70E was held in Salt Lake City on July 18th through July 21st. There were 173 public comments acted on at the meeting. There are a few proposed changes to the standard that were acted upon that may garner the most attention.

NOTE:  The official position of the committee has not been given through the formal ballot. This blog only addresses preliminary revisions proposed by the public and committee.

The first is that the layout of Article 120 Establishing an Electrically Safe Work Condition has been reorganized to better address the logical sequence of events. The steps, principles, and program for lockout/tagout have been moved to be the first sections of Article 120 since these are necessary before verifying the condition.  The verification steps have been moved to the end of Article 120 since these are the last steps for establishing the electrically safe work condition.

A second change is to place further emphasis on the risk assessment and put the hierarchy of controls into mandatory language.  The use of personal protective equipment (PPE) has always been and remains to be the last method selected when providing protection for the worker exposed to hazards when conducting justified energized work. The revised text clarifies this principle.

The third changes clarifies how the standard should have always been used when justified energized work is to be conducted. It essentially is not adding new requirements but will assist in preventing the misuse of the standard. The change is that Table 130.7(C)(15)(A)(a) [that many call the task table] has become a new table applicable to both the PPE category method or the incident energy analysis method. It no longer determines whether PPE is required but whether or not there is a likelihood of an arc flash occurrence. The user conducts a risk assessment and determines the protection scheme to be employed to protect the worker using the hierarchy of controls (same as in the past editions).

The last big change is that the references to PPE equipment standards have been changed to informational notes. The equipment must still meet the applicable standards but the verification process has been changed to one of a conformity assessment where the PPE manufacturer should be able to provide assurance that the applicable standard has been met by one of three methods. The previous edition of the standard did not require any verification method. The three methods are; self-declaration with a Supplier’s Declaration of Conformity, self-declaration under a registered Quality  Management System and product testing by an accredited laboratory and a Supplier’s Declaration of Conformity, or a certification by an accredited independent third-party certification organization.

The committee’s official position will be taken by ballot in early September.  If you want to keep up on the process visit the NFPA 70E web page at www.nfpa.org/70E. The next edition tab will carry all the current information throughout the process. NFPA 70E – 2017 is slated to be voted on at the association meeting in Boston, MA in June 2017.

“Grain Bin Safety” – “Don’t Get Buried Alive….In An Instant”

Video From ABC TV Series “In An Instant”

Grain Bin Safety Week – 15 Tips to Keep You Safe

1.) Maintain grain quality (e.g. moisture, heat, etc)

2.) Never enter a bin without a “bin entry permit”

3.) Never enter a grain bin unless it is really truly necessary

4.) Never enter a grain bin alone – have an outside observer who can both see and hear you

5.) Most young teens do not have the experience, training or qualifications to help you.

6.) Time is of the essence – if you’re engulfed, it takes only 90 seconds for you to die

7.) The outside observer needs to have a sure quick method to contact emergency responders in an emergency

8.) Always lockout unloading equipment before entering (so they can’t be turned on by mistake)

9.) Always check oxygen (min 19.5%) and toxic/inflammable gas levels (phosphine CO2 dust etc) before entry

10.) Always, always use secure a lifeline (harness/rope/ladder) for everyone inside

11.) Ensure that there’s adequate lighting inside  People---Group-of-Firefighters Nationwide Agribusiness

12.) The lifesaving tip of last resort = cross your arms in front of your chest if you’re sinking – so that you can breathe

13.) Even during the most frantic times, never every risk your or anyone else’s life with a 5-minute shortcut

14.) Have a written plan for training and rescue

15.) The most important safety tip – train-and-practice often

Grain bin safety is such an important task that no one should take lightly.

Other great resources:

Learn more about our sponsor Nationwide Agribusiness on YouTube http://www.youtube.com/watch?v=p4zOjiKXz6o – and their website.

Download the “Safe Grain Bin Entry” PowerPoint Presentation Below!

Safe Grain Bin Entry

“RMP Changes Are Almost Here, Stay A Step Ahead”

RMP-update_TF-post

By Timothy P Fagan, Senior Legal Editor

It has been 3 years since the ammonium nitrate explosion in West, Texas, killed 15 people, injured hundreds, and caused widespread damage.  Just a few months after that event, President Obama’s Executive Order (EO) 13650 set into motion actions by numerous government agencies designed to enhance the safety and security of chemical facilities and reduce the risks that hazardous chemicals pose to owners and operators, workers, and communities.

In addition to enhancing cooperation and information sharing among federal agencies and state and local authorities, the activities stemming from EO 13650 included modernizing key regulations, such as U.S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) and OSHA’s Process Safety Management (PSM) Program.  To that end, the EPA recently proposed amendments to RMP regulations under 40 CFR 68, and the Occupational Safety and Health Administration (OSHA) has made policy changes with respect to PSM that will impact how facilities comply with the RMP.

What changes are coming?

The changes to RMP regulations being proposed by the EPA impact the implementation of release prevention programs, the development of emergency response plans, and the sharing of information.

Release prevention programs.  The proposed changes to the accidental release prevention programs include:

  • Requiring all facilities with Program Level 2 or 3 processes to conduct root cause analyses as part of any incident investigation of a catastrophic release or a “near miss.” Identifying the root cause rather than the immediate cause will be more beneficial in preventing similar accidents in the future.
  • Requiring all facilities with Program Level 2 or 3 processes to hire an independent third party to perform a compliance audit after the facility has a reportable release.  Currently, such audits are self-audits, so requiring a third party increases the objectivity of the audit.
  • Requiring facilities in the paper manufacturing, petroleum and coal products manufacturing, and chemical manufacturing sectors with Program 3 processes to conduct a safer technology and alternatives analysis (STAA) as part of the process hazard analysis that must be updated every 5 years.  The facilities must then evaluate the feasibility of any inherently safer technology (IST) identified in the STAA.   The implementation of IST potentially reduces the risk of accidental releases within these industries, which the EPA has identified as having a disproportionate share of reportable releases.

Emergency response plans.  The proposed changes to emergency response plans include:

  • Requiring all facilities with Program Level 2 or 3 processes to coordinate with the local emergency response agencies at least once a year to ensure that resources and capabilities are in place to respond to an accidental release and to ensure that emergency contact information is up to date.  Effective coordination and communication between facilities and emergency responders can reduce the severity of accidental chemical releases.
  • Requiring all facilities with Program Level 2 or 3 processes that have developed their own emergency response plan to conduct a full field exercise at least once every 5 years and one tabletop exercise annually in the other years.   In addition, such facilities that have a reportable accident would be required to conduct a full field exercise within 1 year of the accident.  Such exercises will help ensure that all emergency response personnel understand their roles and responsibilities and be better prepared in the event of a real accident.

Access to information.  The proposed changes to accessing RMP information include:

  • Requiring RMP facilities to provide certain basic information to the public through easily accessible means such as a facility website.  If no website exists, the owner or operator may provide the information at public libraries or government offices or use other means appropriate for particular locations and facilities.
  • Requiring RMP facilities to hold a public meeting after an RMP reportable accident.
  • Requiring certain facilities to provide, on request, local emergency response agencies with summaries of audits, emergency response exercises, investigation reports, and implemented ISTs.
The surprising omission

After the issuance of EO 13650, there was significant speculation that the modernization of RMP regulations would involve additions to the listed chemicals regulated under 40 CFR 68 and a reevaluation of the thresholds at which chemicals became subject to the RMP.  However, the EPA opted not to regulate any additional chemicals under the RMP, nor did the agency change any of the thresholds as part of the recently released proposed regulations.

OSHA’s impact on RMP

Any RMP process that is subject to OSHA’s PSM must comply with Program Level 3 requirements, the most stringent requirements.  Last year OSHA revised its interpretation of the PSM standard’s retail facility exemption, which will result in thousands of facilities no longer being exempt from PSM.  Most of these facilities are already subject to the RMP under Program Level 2, but the change in the exemption interpretation will result in these facilities becoming Program Level 3 facilities.  OSHA will begin enforcing the new exemption interpretation on September 30, 2016, and the EPA will require risk management plan updates within the following 6 months.

What happens next?

For several years there has been speculation about what changes would be made to RMP regulations and how facilities would be impacted.  Now the proposed regulations are here, and facilities must begin the evaluation process.  Facilities must evaluate the proposed regulations and provide comments to the EPA, if necessary, and facilities must evaluate their own programs, procedures, and plans to determine what changes must be implemented to ensure continued compliance with a changing RMP.

“Reminder: Are You In Compliance With OSHA’s New Construction Confined Space Standard?”

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Most employers in the construction industry already know that OSHA issued a new confined space standard for construction that became effective on August 3, 2015. Companies with employees who enter confined spaces at construction sites must be sure to understand the new regulation and adjust their processes in order to remain in compliance. Although the new standard has been in effect for six months, this blog provides a reminder on some of the key provisions of which employers should be aware.

As background, OSHA used to just have a confined space standard for general industry employers (29 CFR 1910.146). However in recognition that construction sites often host multiple employers and are continually changing, with the number and nature of confined spaces changing as work progresses, OSHA promulgated a new standard, available at 29 CFR Subpart AA 1926.1200, tailored to the unique characteristics of construction sites.

While the general industry standard and the construction standard have many similarities, some key differences are:

The construction standard requires coordination when there are multiple employers at the worksite. Specifically, the construction standard imposes duties on three types of employers because of the recognition that different workers may perform different activities in the same space, which can result in hidden dangers:
Entry employers. This is defined as an employer who decides that an employee it directs will enter a permit space. Entry employers have a duty to inform controlling contractors (defined below) of any hazards encountered in a permit space. Entry employers also have to develop safe entry procedures.

Host employers. This is defined as the employer who owns or manages the property where the construction work is taking place. If the host employer has information about permit space hazards, it must share that information with the controlling contractor (defined below) and then the controlling contractor is responsible for sharing that information with the entry employers.

Controlling contractor. This is defined as the employer with overall responsibility for construction at the worksite. The controlling contractor is responsible for coordinating entry operations when there is more than one entry employer. Controlling contractors must provide any information they have about any permit space hazards to all entry employers. The controlling contractor is also responsible for coordinating work in and around confined spaces so that no contractor working at the site will create a hazard inside the confined space. After the entry employer performs entry operations, the controlling contractor must debrief the entry employer to gather information that the controlling contractor then must share with the host employer and other contractors who enter the space later.

Continuous atmospheric monitoring is required under the construction standard “whenever possible.” In contrast, the general industry standard merely encourages continuous atmospheric monitoring where possible and only requires periodic monitoring as necessary.
The construction standard requires that a “competent person” evaluate the work site and identify confined spaces including permit-required confined spaces. Notably, the general industry standard does not require that a “competent person” complete this task. A “competent person” is defined under the new standard as someone who is capable of identifying existing and predictable hazards associated with working conditions, including, of course, whether a workspace is permit-required.

Employers who perform construction-related activities need to make sure they understand the requirements of the new confined space construction standard. For more information, download : Confined Space in Construction: OSHA 29 CFR Subpart AA 1926.1200 here: https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf or consult with your Seyfarth attorney.

Source: Seyfarth, Shaw : Evironmental Safety Update / Law Blog

http://www.environmentalsafetyupdate.com/osha-compliance/are-you-in-compliance-with-oshas-new-confined-space-standard-for-the-construction-industry/

 

 

“Say Goodbye To LOTO: Bring Productivity Back To Safety”

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If deployed correctly, an OSHA exception for Alternative Protective Measures can free your machines from the lockout/tagout productivity killer.

Author(s): Travis Hessman – November 13, 2015

Safety doesn’t have to come at the expense of productivity.”

If one were to boil down the Safety Technology track at EHS Today’s Safety Leadership Conference into one sentence, that would be it.

It was a sentiment that was, of course, welcomed rather warmly by the crowds of EHS professionals in attendance, all of whom have likely been arguing the same point in their plants for years.

But, when Jimi Michalscheck – business development manager at Rockwell Automation – opened with that line in his session on Advanced Lockout/Tagout of all things, he left even that crowd scratching their heads. And for good reason.

In most safety systems (and regulations), there tends to be some wiggle room – space enough for clever engineers to work with the EHS team to maximize safety without interrupting the work process.

“However,” Michalscheck noted, “following OSHA’s lockout/tagout definition, there are certain parameters that you absolutely have to follow. There’s no wiggle room.”

This is what LOTO is for, he explained. No matter what you do, no matter why bypasses operators try to sneak in, the machines are off and everyone is safe.

This, while certainly providing much needed safety for the operators, can add up to some costly downtime.

Michalscheck pointed to a case packer to highlight the point.

These machines, he said, are “notorious for jamming, notorious for interlocks, and notorious for accidents and citations because of the frequency people are in them.”

He estimated that a full LOTO on one of these can take up to 15 minutes to complete and that the machine can jam five times in an hour of operation. That can add up to $23,000 in lost productivity per hour, per machine, he said.

“But what if I told you,” he added, “that we could design a different system that only takes 30 seconds?”

He was referring to an exception tacked on to OSHA’s LOTO requirements (1910.147(a)):

“Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection.”

This means, Michalscheck concluded, that if engineers and EHS teams can work together to create standard safety systems and equipment on their machines to handle these kinds of jams and minor service operations that provide the same measure of safety as full lockouts, then they can go without LOTO.

If deployed appropriately, Alternative Protective Measures (APMs) can provide operators the same safety and security as LOTO, but without the costly downtime.

“You don’t have to shackle your productivity for safety,” he said. “As long as you can design something that is as effective as lockout/tagout, you can do it. In fact, engineering safe alternatives is key to establishing advanced lockout/tagout.”

The trick to this, he said, is to think of your equipment not as single, solid parts, but as a collection of individual serviceable components.

If, for example, a machine mostly jams in one particular area or one particular function, there is not necessarily a need to power down and lock out the entire machine to free it.

Rather, crews can design an alternative safety system that effectively protects workers in an isolated area of the machine, which allows them – protected by guards and triggered e-stops, for example – to quickly free the blockage, correct the errors, and restart the machine with minimal downtime.

These alternative measures, he said, can be powerful productivity tools on the plant floor, but they still require quite a bit of diligence and collaboration to design.

“If you want to do anything other than lockout, I recommend that you treat it just like lockout,” he advised. “Just because OSHA doesn’t require you to document, doesn’t mean you don’t have to do it.”

The means making designing the procedures, documenting them, auditing them, training to them, and incorporating them into your policy and holding yourself to the same bar of safety that OSHA regulations demand.

Developed with care, these systems can provide some much needed wiggle room for the regulations, he said. “But what isn’t allowed is an increased risk to employees by using alternative protective measure procedures. In other words, any APM developed must provide the same or greater level of protection as LOTO.”

“APMs aren’t just an advantage to ROI and competitive edge,” he added. “These are really, really big penalties at stake.” And, it’s worth noting, people’s lives and limbs as well.

Sources: Rockwell Automation, EHS Today & New Equipment Digest

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