7115 Lockout 2019

Background
• Classes: OSHA 10/30 Hour, Incident Investigation,
Confined Space, Excavation Safety, Cranes Signaling,
Rigging Safety, Fall Protection, Scaffold Competent Person,
Silica Competent Person, CHST Prep, Lockout, Machine
Guarding, OSHA Recordkeeping, and Safety Management
• Services: Mock OSHA Inspections, Site Safety Audits,
Expert Witness,
• Since 1987, he has trained over 50,000 people including
OSHA compliance officers and Fortune 500 Clients in
numerous areas of Safety and Health.
1
40 years working with top companies to
achieve world class safety in their sector.
815-354-6853 johnanewquist@gmail.com

Welcome
• Fire/Power Outages
• Restrooms/smoking
• Breaks/lunches
• Student Data Form
• Participant List initial
• DAILY sign-in
• Attendance
• 500 Trainers?
• Introductions/What we
want
• Pretest/Test
• OBJECTIVES

Objectives
• At the end of the training, the
participants will be able to:
• Explain the importance of
energy control programs,
procedures, training, audits and
methods of controlling
hazardous energy.
• Locate and determine
appropriate OSHA Lockout
Standards,
3

Topics
• Hazards and incidents
• Types of hazardous energy,
• Detecting hazardous conditions,
• Implementing control measures as they relate to the
control of hazardous energy,
• Developing and implementing energy control
programs including written isolation procedures,
• Training of authorized and affected employees, and
• Periodic inspection of energy control procedures
using the OSHA control of hazardous energy
standard.

Sep 2018
• Last year, federal OSHA
conducted more than
3,500 inspections under
the Amputations NEP,
constituting more than
10% of all federal OSHA
inspections.
• It found about 7,800
violations and assessed
more than $55 million
in civil penalties.

Control of Hazardous Energy
1910.147
Draft 3 16 2019

1910.147
Lockout/Tagout
Session 1: Definitions, Examining the Need for
Lockout

Definitions
• Affected employee.
• An employee whose job requires
him/her to operate or use a
machine or equipment on which
servicing or maintenance is being
performed under lockout or
tagout, or whose job requires
him/her to work in an area in
which such servicing or
maintenance is being performed.

Affected
• All employees who work in the area
where the energy control
procedure(s) are utilized need to
know about the prohibition against
attempting to restart or reenergize
machines or equipment that is
locked or tagged out.

Definitions
• Authorized employee.
• A person who locks out or tags
out machines or equipment in
order to perform servicing or
maintenance on that machine or
equipment.
• An affected employee becomes
an authorized employee when
that employee's duties include
performing servicing or
maintenance covered under this
section.

Authorized
Needs to be trained in:
• recognition of applicable hazardous
energy sources in the workplace;
• the type and magnitude of energy
found in the workplace;
• the means and methods of isolating
and/or controlling the energy.
Compactors have multiple
energy sources that
require lockout.

Definitions
• Capable of being locked out.
• An energy isolating device is
capable of being locked out if it
has a hasp or other means of
attachment to which, or through
which, a lock can be affixed, or it
has a locking mechanism built
into it.
• Other energy isolating devices are
capable of being locked out, if
lockout can be achieved without
the need to dismantle, rebuild, or
replace the energy isolating
device or permanently alter its
energy control capability.

Definitions
• Energized.
• Connected to an energy source or
containing residual or stored
energy.

Definitions
• Energy isolating device.
• A mechanical device that
physically prevents the
transmission or release of energy.
• Push buttons, selector switches
and other control circuit type
devices are not energy isolating
devices.

Energy Isolating Device
A mechanical device that, when utilized or activated,
physically prevents the transmission or release of
energy, including but not limited to the following:
1. A manually operated electrical circuit breaker;
2. A disconnect switch;
3. A manually operated switch by which the
conductors of a circuit can be
disconnected from all ungrounded supply
conductors, and, in addition, no pole can be operated
independently;
4. A line valve, bolted blank flange and bolted slip
blinds;
5. A block (e.g., a safety block); and
6. Any similar device used to block or isolate energy.

Energy Source
• Any source of:
– Electrical,
– Mechanical,
– Hydraulic,
– Pneumatic,
– Chemical,
– Thermal, or
– Other energy. What kind of energy
did the rock have?

What is hazardous energy?
Energy sources including:
• Electrical
• Mechanical - Kinetic
• Hydraulic
• Pneumatic
• Chemical
• Thermal
• Gravity
• Potential – pressure in vessels
• Radiation
• Other sources in machines
and equipment

Definitions
• Energy source.
• Any source of electrical,
mechanical, hydraulic,
pneumatic, chemical, thermal, or
other energy.

Definitions
• Hot tap.
• A procedure used in the repair,
maintenance and services
activities which involves welding
on a piece of equipment
(pipelines, vessels or tanks) under
pressure, in order to install
connections or appurtenances.
• It is commonly used to replace or
add sections of pipeline without
the interruption of service for air,
gas, water, steam, and
petrochemical distribution
systems.
• This standard does not apply to
the following:
• Hot tap operations involving
transmission and distribution
systems for substances such as
gas, steam, water or petroleum
products when they are
performed on pressurized
pipelines, provided that the
employer demonstrates that-
• continuity of service is essential;
• shutdown of the system is
impractical; and
• documented procedures are
followed, and special equipment
is used which will provide proven
effective protection for
employees.

Definitions
• Lockout.
• The placement of a lockout
device on an energy isolating
device, in accordance with an
established procedure, ensuring
that the energy isolating device
and the equipment being
controlled cannot be operated
until the lockout device is
removed.

Lockout Device
• A device that uses a positive
means such as a lock, either
key or combination type, to
hold an energy-isolating
device in the safe position
and prevent the energizing
of a machine or equipment.

Definitions
• Lockout device.
• A device that utilizes a positive
means such as a lock, either key
or combination type, to hold an
energy isolating device in the safe
position and prevent the
energizing of a machine or
equipment.
• Included are blank flanges and
bolted slip blinds.
blank flanges
slip blinds

Energy Isolating Device: Lines
• Isolation procedures
– Blanking/blinding
– Double block and bleed
– Line breaking
Tank with lines entering it
Is the line or vessel
de-pressurized?

Definitions
• Normal production operations.
• The utilization of a machine or
equipment to perform its
intended production function.

Definitions
• Servicing and/or maintenance.
• Workplace activities such as
constructing, installing, setting up,
adjusting, inspecting, modifying,
and maintaining and/or servicing
machines or equipment.
• These activities include lubrication,
cleaning or unjamming of machines
or equipment and making
adjustments or tool changes, where
the employee may be exposed to
the unexpected energization or
startup of the equipment or release
of hazardous energy.

Definitions
• Setting up.
• Any work performed to prepare a
machine or equipment to
perform its normal production
operation.

Definitions
• Tagout.
• The placement of a tagout device
on an energy isolating device, in
accordance with an established
procedure, to indicate that the
energy isolating device and the
equipment being controlled may
not be operated until the tagout
device is removed.

Definitions
• Tagout device.
• A prominent warning device, such
as a tag and a means of
attachment, which can be
securely fastened to an energy
isolating device in accordance
with an established procedure, to
indicate that the energy isolating
device and the equipment being
controlled may not be operated
until the tagout device is
removed.

The Need for LOTO
• OSHA: failure to control energy accounts for nearly
10 percent of serious incidents.
• Case Studies from the NIOSH report: Guidelines for
Controlling Hazardous Energy During Maintenance
and Servicing reports the following:
Pasta machine

May 2014
• A 17-year-old has the ability to
move his right arm again,
thanks to surgery performed at
Massachusetts General
Hospital.
• Brett Bouchard severed his arm
just below the elbow while
cleaning a pasta machine at
work.

June 2016
• Columbus WI
• The teen was working at the
factory on June 27, 2016
when he was pinned in a
machine while cleaning
scrap from underneath a
laser cutter in operation.
• He later died of his injuries
on July 2, 2016.
• The teen had only been
working there two weeks
when the incident
happened.
This IS my sister-in-law's nephew !!!
Killed at 17 ... all because of company
not following safety rules, providing
proper training and equipment to ensure
lockout/tagout - DA

OSHA Oct 2016
• “We are swamped with
AMPUTATIONS”
• Aurora saw about 100-115
amputations in 2016.
• Inspection is about 40%.
• Many during setup with
machine energized.
• They inspect those with
failure of machine guarding
or lockout.
• The minor servicing
exemption comes into play.

Oct 2018
• A 61-year-old man was killed
Friday after being pulled into a
moving HVAC fan while working
at the AAM Casting
manufacturing plant in
Wauwatosa.
34

Exercise
• “A worker’s first day at work
shouldn’t be his last day on
earth,” was OSHA chief David
Michaels’ reaction to the work-
related death of Lawrence
Daquan “Day” Davis.
• The 21-year old was crushed in a
palletizer machine on August 16,
2012 at the Bacardi Bottling
facility in Jacksonville, FL.
• Davis was a temp worker hired by
Remedy Intelligent Staffing. It
was his first day on assignment to
the Bacardi plant.
What Standards?
Find a 147 c 4, 6, 7 standard

July 2016
• Behr sentenced to probation, $350K restitution in South
Beloit plant worker's death

Aug 2015
• Bumble Bee Foods and two
managers were charged by Los
Angeles prosecutors Monday
with violating safety regulations
in the death of a worker who was
cooked in an industrial oven with
tons of tuna.
• Bumble Bee Foods will pay
$6 million for “willfully
violating worker safety
rules,” according to the Los
Angeles County District
Attorney’s office.
• $1.5 Million to the worker’s
family

Issue?
• What would kill these
workers?

Aug 2016
• Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not establish employment and a place of employment free from
recognized hazards that were causing or likely to cause death or serious
physical harm in that employee(s) were exposed to the hazard of being struck
by the bi-fold door: a) Location: Worcester Academy: On or about December
9, 2015, three employee(s) using a scissor lift to repair the building trim
outside the center bi-fold door in the theater did not affix lockout devices or
otherwise disable the door to prevent unexpected or unintentional operation
of the door. Among other methods, one feasible and reasonable method to
correct this hazard would be to implement and enforce the American National
Standards Institute's standard for personnel protection-lockout/tagout of
energy sources-minimum safety requirements as specified in ANSI Z244.1-
2003(R2014). IN THE ALTERNATIVE: 29 CFR 1910.147(d)(4)(i): Lockout or
tagout devices were not affixed to each energy isolating device by authorized
employees: a) Location: Worcester Academy: On or about December 9, 2015,
employee(s) using a scissor lift to repair the building trim outside the center
bi-fold door in the theater did not lockout or otherwise disable the bi-fold
door to prevent unexpected or unintentional operation of the door.

February 2015
• “Upon arrival, it appeared
that a mechanic was
repairing the brake system
on a commercial truck and
trailer, when the safety
devices failed, causing the
trailer to back over the
mechanic,” the sheriff’s
office said in a late
afternoon press release.
Prevention?

The Need for LOTO
• No national are data available on the number of
fatalities due to contact with uncontrolled hazardous
energy.
• FACE Program: During 1982-1997, NIOSH
investigated 1,281 fatalities.
• 152 involved installation, maintenance, service, or
repair tasks on or near machines, equipment,
processes, or systems.

1979
• December 11
• Northbrook, IL
• Frank Heinrich was killed in an
industrial accident on the
premises of his employer when a
San-Dee Building Maintenance
Company employee activated a
trash compactor while Heinrich
was inside it, causing his death
• $300
• 5(a)(1)
• IL Supreme Court June 29, 1987.
Large trash compactor

The Need for LOTO
• UAW study [1997]: 83 of 414
fatalities among members
between 1973 and 1995 were
due to lockout/tagout
procedures.

January 2015
• A 50-year-old temporary
worker was permanently
disabled after a machine
used to package cases of
bottled water onto a pallet
for shipment started up
while he cleared a jam in
the machine.
• The worker had been on
the job for 12 days at the
Ice River Springs plant in
High Springs, FL.
Is there anything that could jam at
your place?

September 2014
• “There was one male who
was working at this metal
shredding company where
they were bailing what I
believe was metal and in
the process I guess the
machine malfunctioned.
• He went to fix the
malfunction and in the
process the machine
activated and he lost his
life,”
Could the water mixer activate like this?

Exercise
• May 2014
• Paterson, NJ
• After entering a die cutting
machine to do
maintenance, a worker
employed for 26 years at
was crushed when the die
cutter was activated by
another employee unaware
that the victim was inside.
CNC die cutting machine
What places could you be in
and others are unaware you
are in the equipment?

The Need for LOTO
Large injection
molding press

Headlines May 2014
• Company ‘willfully ignored’
safety standards in worker’s
death
• Daniel Collazo (left) was nearly
done with his shift cleaning
machines when other workers
heard his screams.
• Collazo had become caught in the
rotating screws that blend the
hummus and struggled to free
himself as slowly-winding 9-inch
blades kept turning, crushing his
arms and part of his head.
The company paid a $540,000 fine to
the Occupational Safety and Health
Administration following Collazo’s
death in 2011.

Lockout/Tagout
Session 2: Purpose & Scope of Standard

Core Components of an Energy
Control Program
• The employer shall
establish a program
consisting of:
• Energy control procedures,
• Employee training and
• Periodic rendered
inoperative.

Written Programs
• Each state consultation has a
sample program.
• Many are online.

OSHA Nov 2017
• “I’ve seen many images like this
of collaborative robot interactions
that give potential users a false
sense of security.
• ANSI-RIA conformance is no
simple matter there are countless
safety considerations, risk
assessment and validation
measures that are still catching
up to this technology.”

1910.147(a)(1) Scope
• Normal operation is
covered in 1910
Subpart O
• What is Subpart O?

Machine Guarding
• Another example involves adjustments to a printing press while it
is printing.
• The preamble explains that correcting for paper misalignments
using remote control devices is part of the production process,
and is subject to the machine guarding requirements.
• https://www.dol.gov/sol/media/briefs/dayton-10-01-2011.htm

1910.147(a)(3) Purpose
Employers are required to
establish a written program
to:
• affix lockout or tagout
devices to energy isolating
devices
• disable machines or
equipment to prevent
unexpected energization,
start up, or release of
stored energy.

OSHA GM
• “Plain language of lockout/tagout
standard unambiguously renders
it inapplicable when employee is
alerted or warned about
reactivation of machine, given
that term ‘unexpected’ connotes
element of surprise, and there
can be no surprise if employee is
given notice that machine is
being activated.”
• US Court of Appeals - 1996

Jams
• Printing presses may jam, requiring
an employee to bypass the
machine guards in order to reach
the area of the jam and clear it.
• Although the need to unjam the
machine arises during normal
production operations, it is a
servicing activity that involves
employee exposure to unexpected
activation of the machine or
release of energy, and is covered
under the Lockout/Tagout
standard.
• https://www.osha.gov/dts/osta/lot
otraining/hottopics/ht-relche-1-
4.html

Unjamming
• Under no circumstances is any
part of an employee’s body ever
permitted to be exposed within a
hazardous area, such as the point
of operation or in-going nip point
area, during servicing and/or
maintenance activities while the
machine is running or energized.
• https://www.osha.gov/OshDoc/Directive
_pdf/CPL_02-00-147.pdf

1910.147(a)(1)(ii) Exemptions
• Construction, agriculture
and maritime employment;
• Electrical Utilities;
• Electrical equipment
(covered by Subpart S)
• Oil and gas well drilling and
servicing

1910.147(a)(2) Application
• Service and maintenance:
– Employee required to remove or bypass a guard or safety
device
– Employee required to place part of body into area that would
be a danger zone during machine operation cycle

OSHRC GM
• The standard [does not apply] to
servicing and maintenance that
presents minimal and readily
controlled risk . . . .
• [E]ach covered employer’s burden
is determined by the frequency
and complexity of servicing
actually undertaken. . . .
• Machines and equipment that
present no hazard are excluded
from coverage.

OSHRC GM
• Parry testified that once
that gate was opened or an
emergency stop button was
hit, there could be no
startup of any equipment
until another time-
consuming, multi-step
startup procedure was
completed, which
inevitably would alert the
servicing or maintenance
employee.
“Employee could not have
followed proper procedures
and must have entered the
machine area without using the
interlocked barrier gate as
required.”

1910.147(a)(2) Application:
The lockout standard does not
apply to work performed with
electronic equipment that is
connected to its energy source
by a cord and plug.
Exposure to this type of hazard is
controlled by the worker, who
isolates out the equipment by
unplugging it before the
servicing or maintenance and
maintains exclusive control over
the plug.

1910.147(a)(2) Application
• Does not apply to hot tap
operations in transmission and
distribution operations in
pressurized pipelines provided
that:
– Continuity of service is
essential,
– Shutdown of system is
impractical, and
– Documented procedures
and special equipment
provide proven effective
protection for employees

1910.147 LOTO
Authorized Employees – perform LOTO
1910.333 Electrical LOTO
Qualified Employees – perform LOTO
Employers covering electrical work under the 1910.147 LOTO
Program are encouraged to continue to do so. However those
workers need to have additional training and the PPE required for
1910.333(b)(2)(iv).
Compliance with 1910.331-.335 OSHA’s ESRWP & NFPA 70E
Employees must be “qualified” in addition to “authorized”

1910.147 LOTO
Control of Hazardous
Energy
(Hydraulic, Electrical etc.)
1910.333 Electrical LOTO
Shock, burns, fire,
explosion, etc
3 main elements required:
1. Specific documented
procedures
1. Photocopy of the
1910.333(b) is all that is
needed for documented
procedures
2. Training 2. Training per 1910.332 &
NFPA 70E – Qualified
Employee
3. Periodic Inspections 3. No “periodic
inspections” required

Many injuries without the specific procedures needed by 1910.147

May 2014
• Milford, IL
• 3 willful at $70,000 each.
• The worker was clearing
birdseed from a large
industrial mixing tank.
• The worker’s left hand and
arm were crushed after
being caught in the moving
parts of the mixing machine.
• 147(c)(6)(i)
• 147(c)(7)(i)
• 147(d)(4)(i)
The subsequent investigation
determined Wagner’s failed to
lock out energy sources, which
would have protected the worker
from contact with rotating
components of the machine.

147(c)(6)(i)
• The employer shall
conduct a periodic
inspection of the energy
control procedure at
least annually to ensure
that the procedure and
the requirements of this
standard are being
followed.

147(c)(7)(i)
• The employer shall provide
training to ensure that the
purpose and function of the
energy control program are
understood by employees
and that the knowledge and
skills required for the safe
application, usage, and
removal of the energy
controls are acquired by
employees.

147(d)(4)(i)
• Lockout or tagout
devices shall be affixed
to each energy isolating
device by authorized
employees.
What is missing?

Removal
• 1) The use of a master key to remove a
lockout device would be deemed
equivalent (to the removal of the lock by
the person who applied it) only if it is
performed under the employer's
direction and in accordance with the
requirements established in
1910.147(e)(3)
• https://www.osha.gov/laws-regs/standardinterpretations/2000-02-28

Removal
• Specific procedures and training for such
removal have been developed,
documented and incorporated into the
employer's energy control program.
• Verification by the employer that the
authorized employee who applied the
device is not at the facility:
• Making all reasonable efforts to contact
the authorized employee to inform
him/her that his/her lockout or tagout
device has been removed; and
• Ensuring that the authorized employee
has this knowledge before he/she
resumes work at that facility.

Scope
LOTO covers the servicing and
maintenance of machines
and equipment to prevent
injury to workers from:
• unexpected energization or
startup of the machines or
equipment;
• release of stored energy.
How is stored air released
for compressor?

Servicing and Maintenance
Is there a potential for injury
from unexpected startup or
release of stored energy?
Normal production
operations are not taking
place.

Lockout/Tagout:
Minor Servicing Exception

• §1910.147(a)(2)(ii) note.
• Minor servicing activities, which take
place during normal production
operations and which are routine,
repetitive, and integral to the use of
machine/equipment for production,
are not covered by the LOTO standard
if alternative methods provide
effective employee protection from
hazards associated with the control of
hazardous energy (e.g., unexpected
start-up).
• Compliance with the machine guarding
requirements of Subpart O is an
example of such alternative measures.
https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-147.pdf

• Minor tool changes and adjustments, and
other minor servicing activities that take place
during normal production operations, are not
covered by the Lockout/Tagout standard.
• Three specific criteria can be used to
determine if the minor servicing exception
would apply to a particular activity.
• ALL THREE criteria must be met; otherwise
the Lockout/Tagout standard is applicable and
the machine or equipment must be
deenergized and all potentially hazardous
energy rendered safe.

Criteria #1
The activity must be conducted
during normal production
operations, i.e., while the machine
or equipment is actually performing
its intended production function.

Criteria #2
The activity must be:
• Routine: The activity must be a
regular course of procedure and be
in accordance with established
practices.
• Repetitive: The activity must be
regularly repeated as part of the
production process.
• Integral: The activity must be
essential to the production process.

Criteria #3
Employer must use alternative measures
to provide effective protection from the
hazardous energy, such as:
• specially designed tools,
• remote devices,
• interlocked barrier guards,
• local disconnects,
• or control switches which are under
the exclusive control of the employee
performing the minor servicing.
Using an extension tool to
prevent employee injury.

Effectiveness of Alternative Measures
• A CSHO should consider all of the steps taken
by an employer to provide alternative,
effective protection (e.g., training,
disciplinary provisions, engineering controls,
start-up alarms/delays, administrative
provisions, near miss and related-injury data,
etc.) in order to ascertain whether the
alternative, including all of its steps, reliably
prevents an employee from being injured by
hazardous energy when performing servicing
and maintenance activities under the “minor
servicing” exception.

Exception to LOTO
• Definition of Set-up – Any work to prepare a machine to
perform its normal production operation.
• By definition, set-up activities can’t take place during normal
production, so LOTO applies.
What hazards are
there during set of the
lathe?

Example - Not Meeting Exception
• Same machine: the mold
opened up too soon, the
plastic part melts in the
mold, and doesn’t fall.
• Now someone has to go
between mold with hand
tools to pry and scrape off
the material.
• This is not routine or
repetitive; it is done only as
needed, so LOTO would
apply.

Inch Jog
• Inch and jog devices have been included in
the design of machines or equipment in order
to safely perform set-up and to address
maintenance problems associated with the
straightening or feeding of material through
their processes.
• The use of properly designed and applied
control circuitry (such as the use of two hand
activation controls that are designed to
control reliability standards and are mounted
at a predetermined safety distance from the
danger zone) for the testing or positioning of
machine/equipment components, in
conjunction with LOTO, prevent employee
exposure to the hazard associated with the
movement of machine/equipment
components.
• OSHA CPL 2003

Push Buttons
Seven (7) situations can cause unexpected motor
energization or startup if this control circuit method is
used:
a. Another employee enters the motor controller (motor
starter) enclosure and manually closes the relay;
b. A malfunction of the push button;
c. A relay or motor controller failure (e.g., defective spring;
welded contacts). For example, a machine jam occurs
causing higher current in the motor circuit, resulting in the
freeze-up of the controller relay contact parts because the
current creates arcing, which in turn welds shut the relay's
plunger-coil mechanism.
This could be particularly hazardous if an employee is
relying on control circuits to clear jams as the energized
machine could start up and injure the employee;

Seven (7) situations can cause unexpected motor
energization or startup if this control circuit method is
used:
d. A loose wire contacts the conduit or enclosure;
e. Two wires short out inside a damaged conduit (e.g.,
vibration causes wires to rub and wear through the
wire’s insulation resulting in an electric short and
bridging of the control circuit);
f. Water, dirt, metal particles or other conductive foreign
debris enters the control circuit enclosure causing the
switch to operate because the material sufficiently
bridges and closes the circuit, allowing current flow; or
g. Ice, grease, dirt, wood, metal particles or other debris
causes a push type control mechanism to stick in the
closed position, allowing current to flow.
OSHA CPL 2003
Push Buttons cont.

Automated Palletizer
• Operator goes inside
this interlocked gate
to perform minor
servicing, but goes on
the back side out of
sight.
Is this effective
protection?
interlocked gates

LOTO Overview
Lockout/tagout program consists of:
a) survey of all hazardous energy
b) identifying energy-isolating devices
c) selecting and procuring protective materials and hardware
d) assigning duties and responsibilities
e) determining shut-down, de-energization, energization and
start-up sequences
f) written procedures for machines, equipment, and processes
g) training of personnel
h) auditing program elements

EXERCISE
• What is hazardous energy?
• List all Energy sources
Some machines like this plastic injection molder station might have multiple
sources of energy.

Cleaning - Conveyor
• The operator’s assistant wanted to
clean the build-up from the Doser
Conveyor.
• This process uses a high-pressure water
cleaner while the conveyor is in
position and in operational mode.
• His right arm was torn from his torso
from the shoulder.
• A section of guard near the tail drum
had been removed and placed against a
wall.
• A shirt was tightly wrapped around
the axle on one side of the tail drum
• Soft mud was moved from 2 locations
around the tail drum.
• Conveyor was not turned off or
isolated.
Tail Drum

Cleaning - Meat Grinder
• A 15-year-old worker at a
retail grocery store suffered
amputation of the right
arm.
• He was caught by the auger
of a meat grinder.
• The victim was
reassembling parts of a
grinder he had cleaned
without de-energizing and
locking out the machine's
power supply.

Cleaning - Meat Grinder
(continued)
• He inserted the auger into the
grinder's housing and reached
through the feed-throat with his
right hand to guide it into
engagement.
• He bumped against the on/off
switch.
• The grinder started, and the
auger pulled his hand and arm
into the housing.

Control Reliability• Control reliability is generally
considered safety Category-3
or -4 as defined in ISO 13849-
1/ EN954-1 Standard for all
types of circuits.
• This ISO standard regarding
Category-3 states” a single
fault in any of these parts
does not lead to the loss of
the safety function” and that
“a fault shall be detected at
or before the next demand
upon the safety function.”
• And for Category-4, “an
accumulation of undetected
faults shall not lead to the
loss of the safety function.”

Control Reliability
• Two general abnormal conditions can affect valve safety.
• The first is similar to an electrical-control fault, such as
when a relay might be stuck in the open or closed
position.

Control Reliability
• The second abnormal
condition is when a valve
develops diminished
performance, as when a
valve becomes sticky or
sluggish.
• In these cases the valve
reaches the proper
position, but slower
shifting affects safe
stopping distances or
precise timing.

Control Reliability
• The ANSI B11.19- 2003 Standard mandates a monitoring
system that detects these conditions for critical applications
and the ANSI/ PMMI B155.1 standard requires diminished
performance monitoring if stopping time can be affected.
• An easy solution is to use a self-monitoring, Category-3 or -
4 valve, designed to detect both conditions.

De-energized
• Disconnected from all energy sources and not
containing residual or stored energy (isolation).

Energized
• Connected to an energy source OR
• Containing residual or stored energy.

Momentum - Energy
Procedures may require waiting for motion to stop on some machines.
Bull Gears Flywheels

Inspecting - Press
An engineer was
looking at why paper
backing was not
feeding into a press.
His head was caught
between press and
paper roll.
Paper Roll

Jam Clearing
• Many temporary
employees get hurt or
killed when clearing jams.
• Many times machines
start up when a jam is
cleared.
• Lockout is required to
prevent re-energization. A horizontal shaft could restart
once a jam is cleared. Lockout is
required. The shaft needs to be
guarded.

Servicing and Maintenance
– Constructing
– Maintaining and/or servicing
– Installing and setting up
– Adjusting, inspecting,
modifying
– Lubricating, cleaning or un-
jamming
– Tool changes
Note: LOTO applies to all workers
performing these tasks,
regardless of their job titles.

Servicing - Polishing Machine
• 18-year-old employee, had
worked for 2 months.
• Polishing machine stopped.
• He went behind the machine.
• He opened the guard to see if
one of the empty polishing
holders would spin freely.
• He had his hand in there and
hit the start switch.
• The polishers began to spin at
a little over 1,000 rpm.
• What about the guard?

Setup – Die Cutter
• Woman was caught in a die-
cutting machine that she used to
cut graphic art products.
• The woman was pregnant; she
suffered massive head and chest
trauma and lost her baby.
• The company attorney said the
machine had been turned off.
• The woman was preparing her
next job - cutting a sign - and
was far from the control
buttons.
• The machine moved enough to
trap her.[Not actual machine]

Energy Isolating Device- Lines
• Isolation procedures
– Blanking/blinding
– Double block and bleed
– Line breaking
Tank with lines
entering it
Is the line or vessel de-
pressurized?

Setup - Die Changing
• Worker hopes that photo is
enough to convince someone to
lockout equipment.
• Worker was 20 at the time of the
injury, thought he was
“indestructible.”
• He did not follow instructions for
changing out dies.
• Photo was taken on last day of
rehab, a constant reminder of his
mistake.
• Worker is in pain and preparing
for “very early retirement.”

Stored Energy:
Release, Block, or Otherwise Rendered Safe
• Discharge capacitors
• Block or release
springs
• Relieve system
pressure
• Drain fluids
• Vent gases
• Allow system to cool
(or use PPE)
• Allow momentum of
mechanical motion to
stop
Note: some energy sources
have to be addressed by other
means.

Tagout
• Placement of tagout device
– on an energy isolating device,
– in accordance with an
established procedure,
– to indicate that energy
isolating device and
equipment being controlled
may not be operated until
tagout device is removed.

Nucor Trapped Key Variance
1. Modified the electrical controls
2. Installed a trapped key control system
3. Job hazard analysis for roll grinding
- documented an electrical isolation
analysis,
- system and functional safety reviews,
- control reliability analysis
4. Locking the trapped key to the lock box
in the pulpit area inside a
secondary group lock box installed on the
roll mill floor
5. Developed detailed administrative
energy control procedures
6. Implemented detailed administrative
energy control procedures
7. Procured equipment and supplies;
8. English and Spanish for
procedures;
9. Trained authorized and affected
10. Grinding on the passes is
conducted only while using the
administrative energy control
procedures based on the trapped key
system;
11. Installed guarding
12. Minimize the potential for
authorized and affected employees
to enter between the mill stands
when harm could occur; and
13. Designated and posted the areas
as "No Entry"
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_RE
GISTER&p_id=26252 04/08/2016

Work CellsKinetic (mechanical)
energy in the moving
parts of mechanical
systems.

Energy Control Program
• 1910.147(c)(1)
• Written
• Energy control
procedures for each
type of machine
• Training and retraining
to ensure employees
understand the
program
• Periodic inspection to
ensure procedures are
being followed
• Application of energy
controls

1910.147(c)(2)(ii)
• If an energy isolating device is capable of
being locked out, the employer's energy
control program shall utilize lockout.

• Rack out breakers
Pump Panel

How do you know if they
are de-energized?
Pump Gauges

Provide LOTO devices
• A lockout board for employees

Lockout Tags
• Paper tag .
• Not 50 lbs strength.
• Not weather-resistant.

1910.147(c)(3)
Full employee protection
The employer must
demonstrate that the a
tagout system will provide
full employee protection.
Usually OSHA will not
accept tagout.

Feb 2018
What else needs to be done?

1910.147(c)(2)(iii)
• Energy isolating devices
designed to accept lockout
devices whenever:
– Replacement or major repair,
renovation or modification of
equipment is performed, or
– New machines or equipment
are installed.

Session 3:
Energy Control Procedures
Employers must develop and document
machine-specific procedures to control
potentially hazardous energy.

1910.147(c)(4)
Energy control
procedure
• Procedures shall be
developed, documented
and utilized for the control
of potentially hazardous
energy when employees are
engaged in the activities
covered by this section.
• Called Specific Procedures
by OSHA.

1910.147(c)(4)
Energy control procedure
• Outline scope, purpose, authorization, rules, techniques
for control of hazardous energy, including:
– Specific intended use of the procedure;
– Specific steps for shutting down, isolating, blocking
and securing equipment;
– Specific steps for placement, removal, transfer of
lockout/tagout devices and responsibility for them;
– Specific requirements for testing equipment to verify
effectiveness of lockout devices, tagout devices, and
other energy control measures.

Application of the Energy
Control Procedure
(in order)
1. Prepare for shutdown
2. Shut down equipment
3. Isolate all energy sources
4. Apply locks & tags
5. Release stored energy
6. Verify equipment isolation
7. Perform the task
8. Release from Lockout

Step 1: Prepare for Shutdown
• Understand equipment hazards
Before an authorized or affected employee
turns off a machine or equipment, the
authorized employee shall know the type and
magnitude of the energy, the hazards, and the
means to control it.
• Notify other workers

Step 2: Shut Down
Equipment
• Use the normal
shutdown procedures
• Turn all switches to
OFF/Neutral

Step 3: Isolate all Energy Sources
Use energy isolation
devices to prevent
transmission or release
of energy.

Step 4: Apply Locks & Tags
Apply locks and tags to:
• Valves
• Breakers/electrical
disconnects
• Mechanical blocks
Valve lockout device

Step 5:
Release or Block all Stored Energy
• Block/disconnect
lines
• Block or release
springs
• Block elevated parts
• Relieve system
pressure
• Drain fluids
• Vent gases
• Allow system to cool
(or use PPE)
• Apply any additional
locks and tags

Step 6: Verify Equipment Isolation
• Check that other workers are
clear of potential hazards
• Check that locking devices are
secure
• Attempt normal startup
• Return control to OFF/Neutral
Controls to verify
energy isolation

Step 7: Perform the Task
• Perform
maintenance
or service.

Step 8: Release from Lockout
• Ensure machinery is properly assembled and
all tools removed.
• Ensure that employees are outside of danger
zones and are notified that devices are being
removed.
• Remove LOTO devices
–Must be removed by authorized employee
who applied it.

Specific
Procedures
• Many are
pictures
orientation so
use for lockout
procedures.

Specific Procedure Example
• Shutdown the Mixer at the
button.
• Verify that all moving parts have
stopped.
• Lock and tag the knife switch with
appropriate lockout devices. (Be
sure to use your own personal
locks with only one key for each
lock, which you hold.)
• Verify that the mixer is locked out
by pushing on the ON button and
seeing that mixer blades do not
move.
Worker locking out the mixer

Lockout Removal
• To test or reposition
machine/equipment.
• Following sequence must occur:
– Clear machine/equipment of
tools/materials
– Remove employees from area
– Remove Lockout devices
– Energize, test, or reposition
equipment
– De-energize, and reapply energy
control measures before servicing
Machine Guarding must be provided!
Every lock should have
an identifier for each
person locking out.

1910.147(c)(5)
Protective materials
and hardware
• Locks, tags, chains, wedges, key
blocks, adapter pins, self-locking
fasteners, or other hardware shall
be provided by the employer for
isolating, securing or blocking of
equipment from energy sources.

1910.147(c)(5)
Protective materials and hardware
• Lockout and tagout devices must be:
– Singularly identified
– The only device(s) used for controlling
energy
– Not used for other purposes
– And shall meet the following
requirements:

1910.147(c)(5)
• Capable of withstanding environment for
maximum time period
• Moisture or corrosives must not make tag
deteriorate
• Standardized:
– Color
– Shape
– Size
– Print/Format

1910.147(c)(5)
• Lockout and tagout devices indicate identity of
employee applying devices.

Lockout
• Breaker lockout device

Lockout
• Valve lockout device

Lockout
• Gate valves locked out

Lockout
• Multiple locks on a hasp

Electrical Lockout Devices
Locked out electrical
panel
Locked out circuit breaker
Hasp for multiple locks

Group Lock Box
Simplifies lockout of large
equipment.
After machine or process is
locked out, keys are placed
in a lock box.
Each authorized work team
member places a personal
lock or tagout device to the
group lock box.

Improper Valve Lockout
• This photo illustrates the
air line that supplied the
debarker and is not
properly locked out
[courtesy of SCOSHA].
• The insert is a ball-valve
lockout device that can
be used to lock out the
pneumatic airline.

Close Call
• Other people became
involved with the refiner and
needed to lock out the same
breaker.
• They saw the hasp (multiple
lockout device) and placed
their locks on the hasp.
• The millwright was able to
take his lock off the breaker
and remove all other locks.

Pneumatic Valve Isolation Examples
Handle /lever
Note: Some are self-exhausting, but not all.
Piston
Gate Valve

Common Hydraulic Isolation
• Most pumps are
operated by electrical
motors.
• Open and lockout
disconnects for pump
motors.
Hydraulic pumps may be driven by
battery-powered motors, e.g., fork trucks.
Note: All stored energy
including accumulators
must also be relieved.
Disconnect

Valve Isolation
Distilled water line ball valve with
the valve handle perpendicular to
the pipe line (ball valve is closed).
Jaws of the safety lockout hasp pass
through the hole in the valve handle
and a hole fixed in the valve body.
2 padlock shackles (each with a
lockout danger tag) pass through
separate lockout points on the safety
lockout hasp (2 people working on
this task).

Pipe Isolation Examples
Blank Flange Breaking Line
Blocking Line

True “Double Block & Bleed”
PI
Double block and bleed:
method of process isolation
where there are two physical
barriers (valves, blinds, etc.) with
bleed off in between
Each barrier can be operated,
secured, and tested
independently.
Two valves in a series without
bleed-off in-between are counted
as a single valve (barrier).
Chemical
Piping Isolation

VacuBlast Cabinet w/Dust Extractor
• Type Magnitude
• Electrical 415 volts
• Pneumatic 100 psi
• Required Safety
Equipment
• Tagout Tag(s) (2)
• Interlocking Hasp(s) (2)
• Padlock(s) (2)
• Ball Valve Lockout(s)
(1)

Verify Equipment Isolation
• Check that other workers are
clear of hazards.
• Check that locking devices are
secure.
• Attempt normal startup.
• Return control to OFF/Neutral.
Controls to verify
energy isolation

Verification
• Testing circuitry, cycling, visually
inspecting position, manually
trying; monitoring movement or
discharge; observing bleeds,
gauges, indicators, etc; or other
available means.
• Use technique(s) with the best
degree of isolation assurance.
• Do not rely on pressure gages
alone to indicate pressure. They
are often inoperable.

Power Press – LOTO Procedure
Energy Sources:
• Electric motor drive-belt
drive
• Rotating flywheel –
momentum
• Ram/slide - gravity
• Air clutch – 90 PSI line
pressure
Disconnect
Motor

Power Press – LOTO Procedure
Energy Sources:
• Electric motor drive
• Rotating flywheel – momentum
• Ram/slide - gravity
• Air clutch
Procedure:
• Turn off machine and wait until flywheel stops
• Open disconnect and place lock
• Place block under ram
• Close air valve and place lock; listen for air to
bleed off
Verify:
• Try starting motor
• Observe die blocks in place
• Observe flywheel has stopped
• Observe air gage to read 0 pressure
Disconnect
Motor

Lockout Log
A written procedure should be established with a log to
track locations, time, employees and devices.

Session 4:
Required Training
• Authorized employees
– Recognition of hazardous energy sources
– Type and magnitude of energy in the workplace
– Methods for energy isolation / control
• Affected employees
– Purpose and use of energy control procedures
• Other employees in work area
– Procedures related to restarting machines

Training
● Workers clearing jam
need to lockout the
conveyor.
● The conveyor needs
an emergency stop,
guards for
belts/pulleys and
safety trip wires.

Required Training
Employees must be trained in
the following limitations of
tagout systems:
• Tags are warning devices and
do not provide the physical
restraint that is provided by a
lock.
• When a tag is attached to an
energy isolating means, it is
never to be removed without
authorization or ignored.

• Tags must be understandable by all
authorized employees, affected
employees, and all other employees
whose work operations are in the
area.
• Tags and their means of attachment
must be made of materials that will
withstand the environmental
conditions in the workplace.
• Tags may evoke a false sense of
security
• Tags must be securely attached to
energy-isolating devices so that they
cannot be detached during use.
Required Training (cont’d)

Retraining Requirements
Retraining is required in the
following cases:
– Change in job assignments
– Change in machines
– Change in energy control procedures
– Equipment or processes present new
hazards
– Inspections reveal deficiencies in
employee's knowledge of energy
control procedures
Retraining must reestablish
employee proficiency.

Exercise
• Shaft
• Lockout issues?
• Other Issues?

Cleaning Training
• Cleaning a machine is
not supposed to be a
hazard.
• Guards are in place to
prevent exposure to
hazardous motions.
• If guards must be
removed to clean,
lockout is required. Cleaning a conveyor is a common
source of death and amputations. This
conveyor does not have guards for the
rotation of the horizontal drive shafts.

Temps
• Maintenance locks for temp
cleaners is NOT acceptable.
• On December 16, 2011, a
28-year-old male temporary
worker (victim) was fatally
injured while cleaning and
sanitizing a double auger
screw conveyor machine
(feed pump skid).

Session 5:
Periodic Inspections
• 1910.147(c)(6)
• Performed at least annually.
• Conducted by authorized
employees.
• Intended to correct
inadequacies identified in
program.
• Certified.

Periodic Audits
• Machines where
procedures are used
• Date of inspection
• Employees included
in inspection
• Person who
performed
inspection

Audit Interpretation
• “Each energy control procedure
must be separately inspected at
least annually to ensure that the
energy control program is being
properly utilized.”
• March 9, 2004

• “Grouping energy control
procedures for same or similar
machines or equipment for
inspection purposes may
streamline the inspection and
review process, since there will
be a smaller number of
procedure groups than individual
procedures. Thus, an employer
may elect to group procedures as
described above, and then
inspect a representative number
of such employees implementing
one procedure within each group.
“ • November 30, 2010

• “ OSHA interprets this to mean that there must be a review between an
authorized employee designated by the employer as the "inspector"
and all other authorized employees (and all affected employee when
tagout is used to control energy) of the employee's responsibilities
under the periodic inspection being inspected.“
• June 20, 1996

• The periodic inspection consists of two requirements.
• First, the inspector must observe a representative sample of
authorized employees performing the servicing and
maintenance operation using the lockout/tagout procedure.
• Second, the inspector must perform a review with each
authorized employee of that employee's responsibilities under
the energy control procedure being inspected.
• From OSHA Hot Topics - Lockout

Lockout Audits
• For lockout, it's important
for an authorized employee
to actually conduct the
procedure to demonstrate
that the procedure does
work.
• It's also important to test
the e-stops, although this is
better done at the end of
shift because it may be
difficult to get the
automation running again.

Lockout Audits
Audit lockout for new people right away vs waiting a year.

Lockout Audit
• Large Food Processor
• 700 workers
• 40 maintenance
• JSA with Specific
procedure.
• Every non-routine
maintenance is an audit.

Sample Audit Results
• Lockout location info not
correct.
• Contractor padlock not
identified to who it was
protecting.
• PPE for lockout was not
correct for the hazard.

Nov 2018
• You’re a good man!
• Pay attention to the “forgotten
shifts”.
• We have had three fatalities and
over 12 amputations within the
last year on either 2nd or 3rd
shifts.
• Almost all of these companies
had LO/TO programs and training
but had not done any off shift
periodic inspections to verify
compliance.
• Please spread the word!

July 2013
• "Lockout the disconnect
at the knife switch on
the single pole behind
the machine."
• I looked behind the
machine.
• No disconnect.
• The closest disconnect
was to my right. I said I
would lock out this
knife switch.

Interpretation
• “Observing only a single
authorized employee
implementing each lockout
procedure, rather than a
representative number of
employees, also does not meet
the intent of the standard.”
• https://www.osha.gov/dts/osta
/lototraining/case/cs4-1y.html

Session 6: Application of the
Energy Control Procedure
• When the authorized employee who applied the lockout or tagout device
is not available, that device may be removed under the direction of the
employer (if safety is not compromised).
• The specific procedure for removal in this situation includes:

Exception
(cont’d)
• The employer verifies that the
authorized employee who
applied the device is not at the
facility.
• The employer tries to contact
the authorized employee
(before he/she resumes work)
to tell him/her that the lockout
or tagout device has been
removed.

Additional Requirements
Testing or positioning of machines, equipment or components.
If lockout or tagout devices must be removed and the machine
or equipment energized to test or position the machine,
equipment or components, take these steps (in order):

(cont’d)
• Clear the machine or
equipment of tools and
materials in accordance with
paragraph (e)(1) of this
section;
• Remove employees from the
machine or equipment area
(e)(2);
• Remove the lockout or tagout
devices [paragraph (e)(3)].

• Energize and proceed with
testing or positioning;
• De-energize all systems and
reapply energy controls to
continue the servicing
and/or maintenance
[paragraph (d)].
(cont’d)

Who needs
training?
1910.332(a)
Employees in occupations listed
in Table S-4 face such a risk
and are required to be trained.
Other employees who also may
reasonably be expected to face
comparable risk of injury due to
electric shock or other electrical
hazards must also be trained.
 At a minimum, be trained in and familiar
with the following:
 The skills and techniques necessary to
distinguish exposed live parts from other
parts of electric equipment.
 The skills and techniques necessary to
determine the nominal voltage of exposed
live parts, and
 The clearance distances specified in
1910.333(c) and the corresponding
voltages to which the qualified person
will be exposed.

Table S4
➢ Blue collar supervisors
➢ Electrical and electronic
engineers
equipment assemblers
technicians
➢ Electricians
➢ Industrial machine operators
➢Material handling equipment
operators
Typical Occupational Categories of Employees Facing a
Higher Than Normal RIsk of Electrical Accident:
➢ Mechanics and repairers
➢ Painters
➢ Riggers and roustabouts
➢ Stationary engineers
➢ Welders

1910.147(f)(2)
Outside Personnel
• Contractors and other
outside personnel:
– On-site employer and
outside employer inform
each other of lockout/tagout
procedures.
– On-site employer complies
with outside employer’s
energy control program.

1910.147(f)(3)
Group Lockout or Tagout
• Each authorized employee affixes personal
lockout/tagout device to group lockout device when
beginning work.
• Each removes personal device when stopping work
on this equipment.

Outside Contractors
• Must adhere to
standard’s
requirements.
• Must inform each
other of respective
program
responsibilities.

Shift Personnel
• Continuity must be
maintained for
orderly transfer.
• Helps minimize
exposure status, and
release of stored
energy.

Voltage Detectors
• “Senses the steady state
electrostatic ﬁeld produced
by AC voltage through
insulation without requiring
contact to the bare
conductor.
• A red glow at the tip and a
beeping noise (if not
switched OFF) indicates the
presence of voltage.” -
FLUKE
The detector will not work on DC.
Workers must test for the absence
of voltage.

AC Voltage Detectors
Source: Fluke
Read the safety limitations
from the tester mfr

•Worker died when shocked pulling out barrel fuse with pliers
•Electrical circuits must be locked out before doing any work on the
circuits if possible.
Fuse Pulling

Outdoor Signs
Worker found unconscious taking out electric receptacle while
still energized. Breakers were not locked out. No labels in panel.

Other Issues
• Orange disconnects for
the heaters

• Sticker
• Lockout?
Forklift

• Signs?
• Why do people go in?
Boiler

Food Packaging
• One finger amputation.
• Worker went to clear
jam.
• Caught in chain and
sprocket.
• Machine auto started.
• Lack of training.

Wire Drawing
• Severe injuries to
worker setting-up
equipment.
• Caught in wire
• Machine either auto
started or
malfunctioned.
• No lockout.
• Lack of training.

SIGCASE
• $207,450
• Worker cleaning
equipment in preparation
of set-up.
• Equipment not locked
out.
• Worker not trained.
• No specific procedures.
• 5 amputations.

Lockout
• Employee was fixing a
printing press without
de-energizing it.
• Each employee must
lockout if more than
one exposed.

Lockout
• Employee trying to
adjust machine while
running.

Permanent Out of Service
• Question: When equipment is placed in an "out of service" status for
business or production purposes (e.g., poor efficiency, recycled, sold, etc.)
and not related to servicing or maintenance, is the use of lockout/tagout
devices for this purpose a violation of 29 CFR 1910.147(c)(5)(ii)?
• Reply: Yes. As you have stated in your letter, applying lockout/tagout
devices to equipment that was placed out of service for business or
production reasons would not ". . .preserve the integrity of the
Lockout/Tagout program." The preamble to the final rule states, at
54 Federal Register 36671 (Sept. 1, 1989): ". . . the sight of a distinctive
lock or tag will provide a constant message of the use that the device is
being put to and the restrictions which this device is intended to convey. If
lockout or tagout devices are used for other purposes they can lose their
significance in the workplace. For the energy control procedure to be
effective, these devices must have a single meaning to employees: 'Do not
energize the equipment when such a device is affixed to it.'"

November 2015
• This is an IMPROPERLY
wired disconnect
switch.

Exelon EEI and IBEW
• 2005 OSHRC
• The Secretary notes in her
brief that the core principle
of lockout is that each
employee who is potentially
exposed to hazardous energy
will have his own lockout or
tagout device attached to the
energy isolating device
during the servicing
operation and that the
equipment cannot be re-
energized until each
employee removes his own
lock or tag.

Court of Appeals
• OSHA expressly rejected “EEI[’s]
argument that the person removing a
lockout or tagout device need not be
the same as the person who placed
it,” and instead adopted the position
that “each employee must have the
assurance that the device is in his or
her control, and that it will not be
removed by anyone else except in an
emergency situation.”

Consensus Standards
• OSHA recognizes the valuable contributions of national
consensus standards, and in many respects, these
standards offer useful guidance for employers and
employees attempting to control hazardous energy.
• However, the OSH Act contemplates a distinction
between the national consensus standard process and
the process of OSHA rulemaking.
• While the former often produces information useful in
the latter, it is not automatically equivalent
• However, in several important respects, the ANSI
standard appears to sanction practices that may provide
less employee protection than that provided by
compliance with the relevant OSHA provisions.

Hazard Control Hierarchy
Examples:
• Eliminate pinch points (increase
clearance)
• Intrinsically safe (energy
containment)
• Automated material handling
(robots, conveyors, etc.)
• Redesign the process to eliminate
or reduce human interaction
• Reduced energy
• Substitute less hazardous chemicals
Risk Reduction Measure: Elimination or Substitution
Classification: Design Out
Influence on Risk Factors:
• Impact on overall risk (elimination)
by affecting severity and probability
of harm.
• May affect severity of harm,
frequency of exposure to the
hazard under consideration, and/or
the possibility of avoiding or
limiting harm depending on which
method of substitution is applied.

Examples:
• Barriers
• Interlocks
• Presence sensing devices (light
curtains, safety mats, area scanners,
etc.)
• Two hand control and two-hand trip
devices
Risk Reduction Measure: Guards, Safeguarding Devices
Classification: Engineering Controls
• Greatest impact on the probability
of harm (Occurrence of hazardous
events under certain
circumstances)
• Minimal if any impact on severity
of harm

Examples:
• Lights, beacons and strobes
• Computer warnings
• Signs and labels
• Beepers, horns and sirens
Risk Reduction Measure: Awareness Devices
Classification: Administrative Controls
• Potential impact on the probability
of harm (avoidance)
• No impact on severity of harm

Examples:
• Safe work procedures
• Safety equipment inspections
• Training
• Lockout/Tagout/Verify
Risk Reduction Measure: Training and Procedures
of harm (avoidance)

Examples:
• Safety glasses and face shields
• Ear plugs
• Gloves
• Protective footwear
• Respirators
Risk Reduction Measure: Personal Protective Equipment (PPE)
of harm (avoidance)

Provisions for Alternative
Method Interruption
In situations in which alternative methods must be temporarily
discontinued so that the machine or equipment may be
energized to test or position the machine, equipment or
component thereof, the following sequence of actions shall be
followed:
• Clear the machine or equipment of tools and materials.
• Remove affected persons from the machine or equipment
area.
• Temporarily discontinue alternative methods.
• Provide a safe position for persons.
• Position the machine, equipment or process.
• Perform the task.
• When the hazardous energy is no longer needed, reapply the
alternative methods.

Evaluating Alternative Methods
In evaluating an alternative method to lockout or tagout,
the risk reduction measures that will comprise the
alternative method shall be identified. Based on current
analyses and best practices, alternative methods shall
consist of the following parameters as applicable:

Evaluating Alternative Methods
• practicability/justification analysis (clause 8.2.1)
• risk assessment based on the tasks being performed
(clause 8.2.2)
• industry best practices/methods (clause 8.2.3)
• architecture/structure (clause 8.2.4)
• using well-tried components (clause 8.2.5)
• using well-tried designs (clause 8.2.6)
• common cause failure (clause 8.2.7)
• fault tolerance (clause 8.2.8)
• exclusivity of control (clause 8.2.9)
• tamper resistance (clause 8.2.10)
• program to support (clause 8.2.11)
• procedures in place (clause 8.2.12)
• periodic checking and testing (clause 8.2.13)
• review by a qualified person (clause 8.2.14)

March 27, 2007
• OAKDALE, Calif. -- A worker at a
Hershey Co. chocolate factory lost her
arm when a machine she was
cleaning accidentally switched on,
according to the Occupational Safety
and Health Administration.
• Erica Domen, 32, of Modesto, was
cleaning a batter-sifting machine
when the accident occurred at
around 1:20 a.m. Saturday at the
company's Oakdale plant, about 15
miles northeast of Modesto, a
spokesman for the state division of
OSHA said.

Summary
• Machine safety is using lockout
and/or machine guarding.
• Every worker must know where
the hazards are on each machine
• You are either an authorized
employee who is given authority
to lockout or an affected
employee who cannot work on
the machines when trouble
occurs.
When a jam occurs, they must
have lockout or machine
guards. This food packing
machine has inadequate
guards that allow entry into
the point of operation.

7115 Lockout 2019

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