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“Top 10 OSHA Citations of 2016: A Starting Point for Workplace Safety”

OSHAupdate

Every October, the Department of Labor’s Occupational Safety and Health Administration releases a preliminary list of the 10 most frequently cited safety and health violations for the 2016 fiscal year, compiled from nearly 32,000 inspections of workplaces by federal OSHA staff.

One remarkable thing about the list is that it rarely changes. Year after year, our inspectors see thousands of the same on-the-job hazards, any one of which could result in a fatality or severe injury.

More than 4,500 workers are killed on the job every year, and approximately 3 million are injured, despite the fact that by law, employers are responsible for providing safe and healthful workplaces for their workers. If all employers simply corrected the top 10 hazards, we are confident the number of deaths, amputations and hospitalizations would drastically decline.

Consider this 2016 list a starting point for workplace safety:

  1. Fall protection
  2. Hazard communication
  3. Scaffolds
  4. Respiratory protection
  5. Lockout/tagout
  6. Powered industrial trucks
  7. Ladders
  8. Machine guarding
  9. Electrical wiring
  10. Electrical, general requirements

It’s no coincidence that falls are among the leading causes of worker deaths, particularly in construction, and our top 10 list features lack of fall protection as well as ladder and scaffold safety issues. We know how to protect workers from falls, and have an ongoing campaign to inform employers and workers about these measures. Employers must take these issues seriously.

We also see far too many workers killed or gruesomely injured when machinery starts up suddenly while being repaired, or hands and fingers are exposed to moving parts. Lockout/tagout and machine guarding violations are often the culprit here. Proper lockout/tagout procedures ensure that machines are powered off and can’t be turned on while someone is working on them. And installing guards to keep hands, feet and other appendages away from moving machinery prevents amputations and worse.

Respiratory protection is essential for preventing long term and sometimes fatal health problems associated with breathing in asbestos, silica or a host of other toxic substances. But we can see from our list of violations that not nearly enough employers are providing this needed protection and training.

The high number of fatalities associated with forklifts, and high number of violations for powered industrial trucksafety, tell us that many workers are not being properly trained to safely drive these kinds of potentially hazardous equipment.

Rounding out the top 10 list are violations related to electrical safety, an area where the dangers are well-known.

Our list of top violations is far from comprehensive. OSHA regulations cover a wide range of hazards, all of which imperil worker health and safety. And we urge employers to go beyond the minimal requirements to create a culture of safety at work, which has been shown to reduce costs, raise productivity and improve morale. To help them, we have released new recommendations for creating a safety and health program at their workplaces.

We have many additional resources, including a wealth of information on our website and our free and confidential On-site Consultation Program. But tackling the most common hazards is a good place to start saving workers’ lives and limbs.

Thomas Galassi is the director of enforcement programs for OSHA.

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“Top 10 OSHA Citations of 2016: A Starting Point for Workplace Safety”

OSHAupdate

Every October, the Department of Labor’s Occupational Safety and Health Administration releases a preliminary list of the 10 most frequently cited safety and health violations for the 2016 fiscal year, compiled from nearly 32,000 inspections of workplaces by federal OSHA staff.

One remarkable thing about the list is that it rarely changes. Year after year, our inspectors see thousands of the same on-the-job hazards, any one of which could result in a fatality or severe injury.

More than 4,500 workers are killed on the job every year, and approximately 3 million are injured, despite the fact that by law, employers are responsible for providing safe and healthful workplaces for their workers. If all employers simply corrected the top 10 hazards, we are confident the number of deaths, amputations and hospitalizations would drastically decline.

Consider this 2016 list a starting point for workplace safety:

  1. Fall protection
  2. Hazard communication
  3. Scaffolds
  4. Respiratory protection
  5. Lockout/tagout
  6. Powered industrial trucks
  7. Ladders
  8. Machine guarding
  9. Electrical wiring
  10. Electrical, general requirements

It’s no coincidence that falls are among the leading causes of worker deaths, particularly in construction, and our top 10 list features lack of fall protection as well as ladder and scaffold safety issues. We know how to protect workers from falls, and have an ongoing campaign to inform employers and workers about these measures. Employers must take these issues seriously.

We also see far too many workers killed or gruesomely injured when machinery starts up suddenly while being repaired, or hands and fingers are exposed to moving parts. Lockout/tagout and machine guarding violations are often the culprit here. Proper lockout/tagout procedures ensure that machines are powered off and can’t be turned on while someone is working on them. And installing guards to keep hands, feet and other appendages away from moving machinery prevents amputations and worse.

Respiratory protection is essential for preventing long term and sometimes fatal health problems associated with breathing in asbestos, silica or a host of other toxic substances. But we can see from our list of violations that not nearly enough employers are providing this needed protection and training.

The high number of fatalities associated with forklifts, and high number of violations for powered industrial trucksafety, tell us that many workers are not being properly trained to safely drive these kinds of potentially hazardous equipment.

Rounding out the top 10 list are violations related to electrical safety, an area where the dangers are well-known.

Our list of top violations is far from comprehensive. OSHA regulations cover a wide range of hazards, all of which imperil worker health and safety. And we urge employers to go beyond the minimal requirements to create a culture of safety at work, which has been shown to reduce costs, raise productivity and improve morale. To help them, we have released new recommendations for creating a safety and health program at their workplaces.

We have many additional resources, including a wealth of information on our website and our free and confidential On-site Consultation Program. But tackling the most common hazards is a good place to start saving workers’ lives and limbs.

Thomas Galassi is the director of enforcement programs for OSHA.

Safety Photo of the Year: “Why Lock-Out, Tag-Out IS Vitally Important”

Caution: Somewhat Graphic Photo – Note: This Photo is the property of Jack Benton, and may not be used without written consent. Note: I dont know all of the details of this incident and only know that this accident was caused by failure to follow LOTO procedures.

Why LOTO is Vitally Important 3

Why LOTO is Vitally Important 2

Control of Hazardous Energy (Lockout/Tagout)


Introduction

“Lockout/Tagout (LOTO)” refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.

Approximately 3 million workers service equipment and face the greatest risk of injury if lockout/tagout is not properly implemented. Compliance with the lockout/tagout standard (29 CFR 1910.147) prevents an estimated 120 fatalities and 50,000 injuries each year. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation. In a study conducted by the United Auto Workers (UAW), 20% of the fatalities (83 of 414) that occurred among their members between 1973 and 1995 were attributed to inadequate hazardous energy control procedures specifically, lockout/tagout procedures.

LOTO is addressed in specific standards for the general industry, marine terminals, longshoring, and the construction industry.

Standards

This section highlights OSHA standards, preambles to final rules (background to final rules), directives (instructions for compliance officers), standard interpretations (official letters of interpretation of the standards), and national consensus standards related to LOTO.

Note: Twenty-five states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. For the most part, these States adopt standards that are identical to Federal OSHA. However, some States have adopted different standards applicable to this topic or may have different enforcement policies.

OSHA

General Industry (29 CFR 1910)

Marine Terminals (29 CFR 1917)

Longshoring (29 CFR 1918)

Construction Industry (29 CFR 1926)

Preambles to Final Rules

Directives

Standard Interpretations

National Consensus

Note: These are NOT OSHA regulations. However, they do provide guidance from their originating organizations related to worker protection.

American National Standards Institute (ANSI)

Lockout/Tagout Concepts

“Lockout/Tagout (LOTO)” refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities. This requires that a designated individual turns off and disconnects the machinery or equipment from its energy source(s) before performing service or maintenance and that the authorized employee(s) either lock or tag the energy-isolating device(s) to prevent the release of hazardous energy and take steps to verify that the energy has been isolated effectively. The following references provide information about the LOTO process.

  • Lockout/Tagout. National Ag Safety Database (NASD) Research Publications-11. Also available as a 49 KB PDF, 2 pages.
  • Lockout/Tagout [212 KB PDF*, 2 pages]. OSHA Fact Sheet, (2002). A Spanish version [49 KB PDF*, 1 page] is also available.
  • Preventing Worker Deaths from Uncontrolled Release of Electrical, Mechanical, and Other Types of Hazardous Energy. US Department of Health and Human Services (DHHS), National Institute for Occupational Safety and Health (NIOSH) Publication No. 99-110, (1999, August).
  • Guidelines for Controlling Hazardous Energy During Maintenance and Servicing [Lockout/Tagout]. US Department of Health and Human Services (DHHS), National Institute for Occupational Safety and Health (NIOSH) Publication No. 83-125, (1983, September).

Lockout/Tagout Program

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

Additional Information

Related Safety and Health Topics Pages

Training

  • Small Business Handbook. OSHA Publication 2209-02R, (2005). Also available as a 260 KB PDF, 56 pages.
  • Lockout/Tagout. National Ag Safety Database (NASD). Provides an index to several training videos available through NASD.
  • Rollstock and Sheet Extrusion Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating an extrusion molding machine and ways to avoid those injuries.
  • Injection Molding Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating an injection molding machine and ways to avoid those injuries.
  • Roll-fed and Inline Thermoforming Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating roll-fed and inline thermoforming machines.

“Conduct A Lockout – Tagout Scavenger Hunt At Your Company!” #Brady

  

Brady’s latest infographic encourages viewers to conduct a lockout/tagout scavenger hunt in their facilities. “It’s one thing to talk about the components needed for lockout tagout, it’s another to get out on the floor and locate them,” says Brady’s Tim Bandt, noting that the infographic is an effective way to make sure employees are familiar with a site’s lockout/tagout program and related tools. “This infographic helps employers evaluate their program and determine if there are any gaps to improve on.” The infographic includes a series of questions to guide users on a site walk through to find six important elements of a lockout/tagout program. Download PDF file of the above sign below and check your facility today. Great for employee involvement!

LOTO Scavenger Hunt PDF

Free Whitepaper: “10 Tips To Implementing A Lockout / Tagout Program”

Lock out tag out program

10 Tips to Implementing a Lockout/Tagout Program

Your LOTO program must address the hazards that workers face when they place any part of their body near a machine’s point of operation, power transmission apparatus, pinch points, or other moving parts during maintenance and servicing activities. If the machine is not properly shut down and secured, it could unexpectedly start up, release stored energy, move, or cycle, causing crushing injuries, amputations, or even fatal injuries. A well-designed LOTO program can prevent these injuries.

This paper gives you 10 tips for ensuring that your LOTO program is well-designed and effective, and that it avoids some of the more common failure points found in LOTO programs.

Click here to download this free paper today!

Safety Photos of the Day – “Why Lock-Out, Tag-Out IS Vitally Important” – Part II

Caution: Somewhat Graphic Photos – Not for the faint of heart.

LOTO 2 October 2013 LOTO 2A October 2013

A cotton factory worker fell unconscious while standing up after his head became clamped in a machine. The incident happened in Wenzhou, eastern China’s Zhejiang Province. After the worker became trapped emergency services were called to help free him. When firefighters arrived at the factory they found the worker had lost consciousness, but he was held upright because his head was clamped by a machine. Lack of  using LOTO, Trip Sensors & Guarding were deemed to be the cause of the accident.

 

Control of Hazardous Energy (Lockout/Tagout)


Introduction

“Lockout/Tagout (LOTO)” refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.

Approximately 3 million workers service equipment and face the greatest risk of injury if lockout/tagout is not properly implemented. Compliance with the lockout/tagout standard (29 CFR 1910.147) prevents an estimated 120 fatalities and 50,000 injuries each year. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation. In a study conducted by the United Auto Workers (UAW), 20% of the fatalities (83 of 414) that occurred among their members between 1973 and 1995 were attributed to inadequate hazardous energy control procedures specifically, lockout/tagout procedures.

LOTO is addressed in specific standards for the general industry, marine terminals, longshoring, and the construction industry.

Standards

This section highlights OSHA standards, preambles to final rules (background to final rules), directives (instructions for compliance officers), standard interpretations (official letters of interpretation of the standards), and national consensus standards related to LOTO.

Note: Twenty-five states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. For the most part, these States adopt standards that are identical to Federal OSHA. However, some States have adopted different standards applicable to this topic or may have different enforcement policies.

OSHA

General Industry (29 CFR 1910)

Marine Terminals (29 CFR 1917)

Longshoring (29 CFR 1918)

Construction Industry (29 CFR 1926)

Preambles to Final Rules

Directives

Standard Interpretations

National Consensus

Note: These are NOT OSHA regulations. However, they do provide guidance from their originating organizations related to worker protection.

American National Standards Institute (ANSI)

Lockout/Tagout Concepts

“Lockout/Tagout (LOTO)” refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities. This requires that a designated individual turns off and disconnects the machinery or equipment from its energy source(s) before performing service or maintenance and that the authorized employee(s) either lock or tag the energy-isolating device(s) to prevent the release of hazardous energy and take steps to verify that the energy has been isolated effectively. The following references provide information about the LOTO process.

  • Lockout/Tagout. National Ag Safety Database (NASD) Research Publications-11. Also available as a 49 KB PDF, 2 pages.
  • Lockout/Tagout [212 KB PDF*, 2 pages]. OSHA Fact Sheet, (2002). A Spanish version [49 KB PDF*, 1 page] is also available.
  • Preventing Worker Deaths from Uncontrolled Release of Electrical, Mechanical, and Other Types of Hazardous Energy. US Department of Health and Human Services (DHHS), National Institute for Occupational Safety and Health (NIOSH) Publication No. 99-110, (1999, August).
  • Guidelines for Controlling Hazardous Energy During Maintenance and Servicing [Lockout/Tagout]. US Department of Health and Human Services (DHHS), National Institute for Occupational Safety and Health (NIOSH) Publication No. 83-125, (1983, September).

Lockout/Tagout Program

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

Additional Information

Related Safety and Health Topics Pages

Training

  • Small Business Handbook. OSHA Publication 2209-02R, (2005). Also available as a 260 KB PDF, 56 pages.
  • Lockout/Tagout. National Ag Safety Database (NASD). Provides an index to several training videos available through NASD.
  • Rollstock and Sheet Extrusion Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating an extrusion molding machine and ways to avoid those injuries.
  • Injection Molding Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating an injection molding machine and ways to avoid those injuries.
  • Roll-fed and Inline Thermoforming Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating roll-fed and inline thermoforming machines.

Safety Photos of the Year: “Why Lock-Out, Tag-Out IS Vitally Important”

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

labour_accident_02

labour_accident_01

Control of Hazardous Energy (Lockout/Tagout)


Introduction

“Lockout/Tagout (LOTO)” refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.

Approximately 3 million workers service equipment and face the greatest risk of injury if lockout/tagout is not properly implemented. Compliance with the lockout/tagout standard (29 CFR 1910.147) prevents an estimated 120 fatalities and 50,000 injuries each year. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation. In a study conducted by the United Auto Workers (UAW), 20% of the fatalities (83 of 414) that occurred among their members between 1973 and 1995 were attributed to inadequate hazardous energy control procedures specifically, lockout/tagout procedures.

LOTO is addressed in specific standards for the general industry, marine terminals, longshoring, and the construction industry.

Standards

This section highlights OSHA standards, preambles to final rules (background to final rules), directives (instructions for compliance officers), standard interpretations (official letters of interpretation of the standards), and national consensus standards related to LOTO.

Note: Twenty-five states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. For the most part, these States adopt standards that are identical to Federal OSHA. However, some States have adopted different standards applicable to this topic or may have different enforcement policies.

OSHA

General Industry (29 CFR 1910)

Marine Terminals (29 CFR 1917)

Longshoring (29 CFR 1918)

Construction Industry (29 CFR 1926)

Preambles to Final Rules

Directives

Standard Interpretations

National Consensus

Note: These are NOT OSHA regulations. However, they do provide guidance from their originating organizations related to worker protection.

American National Standards Institute (ANSI)

Lockout/Tagout Concepts

“Lockout/Tagout (LOTO)” refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities. This requires that a designated individual turns off and disconnects the machinery or equipment from its energy source(s) before performing service or maintenance and that the authorized employee(s) either lock or tag the energy-isolating device(s) to prevent the release of hazardous energy and take steps to verify that the energy has been isolated effectively. The following references provide information about the LOTO process.

  • Lockout/Tagout. National Ag Safety Database (NASD) Research Publications-11. Also available as a 49 KB PDF, 2 pages.
  • Lockout/Tagout [212 KB PDF*, 2 pages]. OSHA Fact Sheet, (2002). A Spanish version [49 KB PDF*, 1 page] is also available.
  • Preventing Worker Deaths from Uncontrolled Release of Electrical, Mechanical, and Other Types of Hazardous Energy. US Department of Health and Human Services (DHHS), National Institute for Occupational Safety and Health (NIOSH) Publication No. 99-110, (1999, August).
  • Guidelines for Controlling Hazardous Energy During Maintenance and Servicing [Lockout/Tagout]. US Department of Health and Human Services (DHHS), National Institute for Occupational Safety and Health (NIOSH) Publication No. 83-125, (1983, September).

Lockout/Tagout Program

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

Additional Information

Related Safety and Health Topics Pages

Training

  • Small Business Handbook. OSHA Publication 2209-02R, (2005). Also available as a 260 KB PDF, 56 pages.
  • Lockout/Tagout. National Ag Safety Database (NASD). Provides an index to several training videos available through NASD.
  • Rollstock and Sheet Extrusion Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating an extrusion molding machine and ways to avoid those injuries.
  • Injection Molding Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating an injection molding machine and ways to avoid those injuries.
  • Roll-fed and Inline Thermoforming Machine Safety Training Course. OSHA and the Society of the Plastics Industry, Inc. (SPI) Alliance. Contains machine-specific modules on machine guarding and lockout/tagout and helps to identify the types of injuries that can occur while operating roll-fed and inline thermoforming machines.

 

Chicago Suburban Contract Safety Job Opportunity – Elk Grove Village – 3 Months – Food Manufacturer – Writing LOTO Procedures

image0011

Contract OpportunityElk Grove Village – 3 months – Food Manufacturer – Writing LOTO Procedures – Contact the Recruiter Directly! (Please Mention My Name When You Call Her!)

Details:

Elk Grove Village – 3 months – Food Manufacturer

– Looking for someone to write Lock Out Tag Out  procedures
– Needs at least 3-5 years of experience writing these procedures
– Needs knowledge of OSHA standards
– No degree required

Deshanna Crockett
TECHNICAL RECRUITER

STERLING ENGINEERING
Corporate Office
977 North Oak Lawn Avenue
Elmhurst, IL 60126
Direct: 630-993-3403
Email: dcrockett@sterling-engineering.com

 

Lockout-Tagout Interactive Training Program

The Directorate of Technical Support and Emergency Management presents the 29 CFR 1910.147, Lockout/Tagout Interactive Training Program. We developed the program jointly with the Directorates of Enforcement Programs, Safety Standards and Guidance, the Office of Training and Education, and the Office of the Solicitor. Compliance officers in Philadelphia, New York, and Atlanta assisted us as well.

Whether you are a recent hire or an experienced employee, this program will expand your knowledge of the Lockout/Tagout (LOTO) standard.

The program has three major components. You can go through these components at your own pace and in any sequence:

Tutorial: Explains the standard in a question/answer format.

Hot topics: Contains five abstracts with a detailed discussion of major issues. Relevant highlighted sections of the all-inclusive documents are linked here.

Interactive case studies: Seven simulated LOTO inspections are presented. You will be making decisions on the application of the LOTO standard, based on information presented on the screen.

What OSHA Expects: The Electrical & Arc Flash Safety Questions OSHA Will Ask During an Investigation

When it comes to electrical safety, OSHA standards can be technical and confusing. What requirements do safety managers need to know?

Wouldn’t it be nice to know exactly what OSHA is training its inspectors to look for during an inspection that includes electrical safety, including surprising new areas of emphasis based on national OSHA directives?

This article covers some of the typical electrical safety questions that OSHA inspectors will ask during a field investigation, what they mean and how to be prepared and in compliance.

A good starting point is to understand OSHA’s approach to electrical safety. OSHA’s goal is for employers to identify all electrical hazards, both potential and actual. In the past, OSHA focused on process changes, encouraging companies to de-energize circuits before working on them, perform lockout/tagout procedures and develop ongoing safety programs that include worker training and retraining. A more recent area of emphasis is arc flash safety, which means electrical safety professionals must analyze the workplace for shock and arc flash hazards, establish safe protection boundaries and define what personal protective equipment (PPE) must be used within these boundaries.

For electrical safety in the workplace, OSHA relies on expert consensus bodies such as the National Fire Protection Association (NFPA) and its standards published in NFPA 70E. To ensure that employers are following NFPA and OSHA guidelines, OSHA trains its inspectors and compliance officers to ask specific questions in the event of an electrical safety incident. Some typical questions follow.

Is there a description of the circuit or equipment at the job location?

OSHA expects employers to know their workplaces. If an employer cannot provide a written description or drawing of the circuit or equipment, then the compliance officer may assume that the employer has not assessed the facility for electrical hazards.

Is there a detailed job description of planned work?

In order to know which safety procedures to use, the worker must be provided with a description of the job task. OSHA publication 29 CFR 1910 lays out employer responsibilities for protecting their workers from electrical safety hazards. It states that the employer shall train workers to use safe work practices that are designed to avoid injury.

Can you justify why equipment cannot be de-energized or the job deferred until the next scheduled outage?

Per OSHA 1910.333(a)(1), live parts to which an employee may be exposed must be de-energized before the employee works on or near them, unless the employer can demonstrate that de-energizing introduces additional or increased hazards or is  not feasible due to equipment design or operational limitations. (Live parts that operate at less than 50 volts to ground need not be de-energized if there will be no increased exposure to electrical burns or to explosion due to electric arcs.)

The message is clear: never work on live circuits unless it is absolutely necessary. OSHA allows work on live circuits in some cases, but the reason cannot be simply that turning off the power is inconvenient or will interrupt production. Nor can workers use the excuse that they didn’t have the authority to shut off power.
When it is necessary to perform work on energized equipment, OSHA 1910.333(a)(2) requires safety-related work practices to be used and NFPA 70E Article 110.8(B)(1) requires an Electrical Hazard Analysis before work is performed on live equipment operating at 50 volts and higher.

Other questions you can expect from an OSHA inspector include:

  • What about safe work procedures?
  • Has a detailed work procedure been established?
  • Are there detailed descriptions of work practices to be employed?
  • Was a job briefing checklist performed, and was the job briefing completed for those performing the work?
  • Was proper management approval secured?

OSHA wants employers to make electrical safety procedures and practices part of regular work processes. Several annexes to NFPA 70E offer guidelines for lockout/tagout procedures, checklists and approvals. For example, Annex E covers Electrical Safety Programs, Annex F covers Hazard Risk Evaluation Procedures, Annex I covers Job Briefing Checklists and Annex J covers Energized Work Permits.

NFPA 70E annexes are not strictly “enforced” by OSHA, as they are appendices to the NFPA standard. However, OSHA inspectors and investigators will ask if the content and information contained in these annexes was followed and adhered to.

As an EHS professional, would you know the answers to these questions if an OSHA inspector came knocking on your door?

  • Were required electrical safety analyses performed?
  • Was an arc flash hazard analysis performed?
  • Were flash protection boundaries established?
  • Were all other potential electrical hazards identified?

OSHA regulations state that every employer shall furnish a place of employment free from recognized hazards that are causing or likely to cause death or serious physical harm, and that the employer must assess the workplace to determine if hazards are present and select PPE to protect employees.  When it comes to electrical safety, OSHA refers to NFPA 70E, which requires employers to conduct an electrical hazard assessment consisting of a shock hazard analysis and an arc flash hazard analysis before work is performed on live equipment operating at 50 volts and higher.

These requirements may be fairly complex, as they involve calculating the potential fault current at each piece of equipment, understanding the characteristics of the overcurrent protective devices and how they are coordinated for each circuit and creating or updating one-line electrical drawings. Complex or not, OSHA inspectors are trained to ask if these analyses were performed, because they are essential to reducing the number of arc flash-related deaths and injuries that occur each year, as well as ensuring a safe installation.

When the safety of any job task involves electricity or electrical equipment, ask yourself these questions:

  • Were proper tools and equipment used?
  • Was the necessary PPE determined?
  • Were the proper insulated tools used?
  • Were insulated blankets and/or sheeting used to properly cover all of the live parts?

OSHA 1910.132 requires employers to assess hazards, select PPE and make sure that employees are trained how to use it. Electrical PPE, safe work practices such as lockout/tagout and safety training are covered by OSHA 29 CFR 1910.301-.399, also known as Electrical Subpart S.

For example, OSHA 1910.333 (a)(1)(i) states:  “Employees working in areas where there are potential electrical hazards shall be provided with and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.”

For electrical workers, this standard’s effect is multi-fold. First, employers must facilitate workers’ understanding of the PPE required for each task on each piece of equipment. This may be communicated via a work order, a descriptive label on the equipment or a one-line drawing. Second, employers must select the PPE, which includes insulated tools and protective clothing. Third, the employer is required to train workers in safe work practices – and in particular, how to match the PPE to the level of the electrical hazard. And finally, OSHA 1910.269(a)(2)(iii) requires employers to “determine, through regular supervision and through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices …”

Were the workers performing the tasks qualified to do so?

OSHA defines qualified workers as those specially trained to work on live electrical equipment. Qualified workers must protect themselves against all electrical hazards including shock, arc flash, burns and explosions. Training is key. Even an experienced electrician is not “qualified” in OSHA’s eyes unless the employer can show proof of the appropriate training and certifications.

OSHA 1910.332(b)(2) also requires unqualified workers to be trained in the electrical safe work practices that are necessary for their safety. Unqualified workers, such as painters or cleaners, occasionally come into contact with energized equipment, and therefore they must be trained to recognize and avoid electrical hazards.

Kenneth Cybart, senior technical sales engineer at Littelfuse, trains managers how to keep electrical workers safe and meet OSHA and NFPA standards. He has 20 years of experience in circuit protection applications, has authored several electrical safety articles and has been a speaker at industry events. He can be reached at kcybart@littelfuse.com.

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