Lockout/Tagout Training (Contractor Version)


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This training presentation targeted at Contractors and Electricians covers the importance of Lockout/Tagout as a form of mitigation, the necessary elements of an effective program for the control of hazardous energy along with the means of handling special cases within the program.

Published in: Business, Health & Medicine

Lockout/Tagout Training (Contractor Version)

  1. 1. Lockout-Tagout Training SM
  2. 2. Agenda • Why is Lockout/Tagout (LOTO) important? • How does LOTO apply to contractors? • What is required for compliance? • How to establish an energy control program? SM
  3. 3. Why is LOTO important? SM
  4. 4. Risk Mitigation Employee Safety Legal Risk Mitigation Financial SM
  5. 5. Employee Safety • Approximately 3 million workers in the US service equipment and face the greatest risk of injury if Lockout/Tagout is not properly implemented • Lockout/Tagout prevents an estimated 120 fatalities and 50,000 injuries each year in the US. • Workers injured from exposure to hazardous energy lose an average of 24 workdays for recuperation Source: http://www.osha.gov/SLTC/controlhazardousenergy/index.html SM
  6. 6. Legal Risk • Created under the Occupational Safety and Health Act of 1970 • Only government regulatory agency for workplace safety • Instructs, conducts inspections and enforces workplace safety • Does not apply to government facilities OSHA General Duty Clause States: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” SM
  7. 7. State Plans • Twenty-four states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans • Job safety and health standards must be "at least as effective as" comparable federal standards. • Most States adopt standards identical to federal ones -- States have the option to promulgate standards covering hazards not addressed by federal standards. SM
  8. 8. Legal Risk OSHA Standards • Required by law for employers to follow • Requirements in General Terms • Lots of details but also rely on consensus industry standards for guidelines NFPA 70E – 2009 (Originated 1976) • Details – safe installation, maintenance and work practices, signs, PPE (Personal Protective Equipment), shock hazard and AF analysis… • Only applies to electrical energy (Electrically Safe Working Condition) FINAL RULE 72:7135-7221 in Aug 2007: “The Occupational Safety and Health Administration (OSHA) is revising the general industry electrical installation standard found in Subpart S of 29 CFR Part 1910. The Agency has determined that electrical hazards in the workplace pose a significant risk of injury or death to employees, and that the requirements in the revised standard, which draw heavily from the 2000 edition of the National Fire Protection Association's (NFPA) Electrical Safety Requirements for Employee Workplaces (NFPA 70E), and the 2002 edition of the National Electrical Code (NEC) , are reasonably necessary to provide protection from these hazards. SM
  9. 9. Legal Risk OSHA Standard 29 CFR 1910.147: • Adopted in 1989 • Applies to general industry employment • Covers about 39 million workers • Established minimum performance requirements for the control of hazardous energy • Covers the servicing and maintenance of machines and equipment in which the unexpected start-up or the release of stored energy could cause injury • Applies to all types of energy: mechanical, hydraulic, electrical, gas, pneumatic, water, chemical, thermal, SM etc…
  10. 10. Legal Risk NFPA 70E – Chapter 1 Article 110 States: “covers electrical safety-related work practices and procedures for employees who work on or near exposed energized electrical conductors or circuit parts in workplaces that are included in the scope of this standard” “Intended to provide for employee safety relative to electrical hazards in the workplace” Source: NFPA Regulations – Chapter 1, Article 110, 2009 SM
  11. 11. Top OSHA Violations SIC Code ‘D’ = Manufacturing SM
  12. 12. Financial Risk  Downtime • Personnel • Equipment  Legal Action • Liability and Injury • Cost of outside counsel  Fines and Penalties: • LOTO is #3 most cited by OSHA • Fiscal Year 2006  38,579 federal OSHA site inspections  58,058 state OSHA site inspections Source: Occupational Hazards, February 2008  3,659 violations for LOTO totaling about $6M SM
  13. 13. Financial Risk SM
  14. 14. Risk Mitigation Conclusion: “The costs in terms of human suffering, lost productivity, worker’s compensation claims and lawsuits can far outweigh the investment in a comprehensive program.” Source: Occupational Health&Safety Volume 76, Number 10 SM
  15. 15. How does LOTO apply to contractors? SM
  16. 16. Lockout/Tagout for Construction SM
  17. 17. Lockout/Tagout • 1926.417 is very brief • 1926.21 mandates training to avoid unsafe conditions • 1910.147 provides LOTO best practices even though it does not directly apply to Construction Industry. • 1910.333 (Selection and use of work practices) provides additional best practices for safely dealing with electrical energy. • OSHA General Duty Clause • When do you fall under 1910 versus 1926?  In the end, proper Lockout/Tagout is for your safety! SM
  18. 18. What is required for LOTO compliance? SM
  19. 19. Elements of a Lockout/Tagout program  Procedures  Training  Device requirements  Inspections SM
  20. 20. Procedures  OSHA 1910.147(c)(4)(i) “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”  NFPA 70E 120.2 (F) / Ch. 5-4 “The employer shall maintain a copy of the procedures required by this section and shall make procedures available to all employees” SM
  21. 21. Procedures Procedures shall be developed, documented and utilized for the control of potentially hazardous energy: – Steps to de-energize and re-energize – Lockout/Tagout devices to utilize – Drawings/diagrams (equipment specific) – What employees are exposed to hazards? – Who is qualified to perform LOTO? – Who is in charge of the LOTO program? Standards/Codes: OSHA 1910.147(c)(4); NFPA 70E - Article 120.2 (D) & (F), and Annex G SM
  22. 22. Procedures Steps for equipment shutdown 1. Prepare for and announce shutdown 2. Shutdown equipment 3. Disconnect energy sources / test for isolation 4. Lockout and/or Tagout 5. Release stored energy 6. Verify isolation SM
  23. 23. Procedures Steps for equipment startup 1. Verify equipment operationally intact - Clear all personnel and tools 2. Ensure employees are safely positioned 3. Remove lockout/tagout devices from each energy-isolating device 4. Notify all affected employees of Lockout/Tagout removal and that work has been completed 5. Start equipment SM
  24. 24. Training OSHA 1910.147(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” NFPA 70E 120.2 (B) (2) “Each employer shall provide training as required to ensure employees’ understanding of the lockout/tagout procedure content and their duty in executing such procedures” SM
  25. 25. Training Authorized employees – person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment Affected employees – 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 SM
  26. 26. Training Authorized employees:  Recognition of applicable hazardous energy sources  Type and magnitude of energy available in the workplace  Methods and means necessary for energy isolation and control  Ways to verify that the energy isolation is effective SM
  27. 27. Training Affected employees:  Instructed in the purpose and use of energy control procedure  Should never attempt to restart or re-energize machines or equipment which are locked out or tagged out  Respect use of warning tags SM
  28. 28. When Should a Company Retrain?  New employees, or change in employee responsibilities  New equipment, or change in machines, equipment or processes that present a new hazard or change to energy control procedures  Deviations from, or inadequacies in, the employee’s knowledge or use of the energy control procedure SM
  29. 29. Device Requirements OSHA 1910.147(c)(7)(i) “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 a safe position and prevent the energizing of a machine or equipment” NFPA 70E 120.2 (E) (2) “Each employer shall supply, and employees shall use, lockout/tagout devices and equipment necessary to execute the requirements of 120.3(E). Locks and tags used for control of exposure to electrical energy hazards shall be unique, shall be readily identifiable as lockout/tagout devices, and shall be used for no other purpose.” SM
  30. 30. Device Requirements Lockouts must be:  Used only to control energy  Durable enough for use in their environment  Standardized by either color, shape or size  Substantial – withstand all but excessive force  Identify the employee applying the device SM
  31. 31. Device Requirements Tags must be:  Durable enough for use in their environment  Substantial – enough to resist accidental or inadvertent removal  Standardized by either color, shape or size  Identify the employee responsible for the Tagout  Non-reusable attachment device & attachable by hand  Withstand 50 lbs of force SM
  32. 32. Inspection OSHA 1910.147(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.” NFPA 70E 120.2 (C) (3) “An audit shall be conducted at least annually by a qualified person and shall cover at least one Lockout/Tagout in progress and the procedure details. The audit shall be designed to correct deficiencies in the procedure or in employee understanding.” SM
  33. 33. Inspection  At least annually  Performed by authorized employee, other than the one(s) using the energy control procedure  Cover Lockout/Tagout in progress  Between inspector and authorized/affected employees • Lockout – review employees responsibilities under the energy control procedure inspected • Tagout – review employee responsibilities and Tagout limitations  Document inspection  Correct any deviations or inadequacies identified SM
  34. 34. Outside Personnel • Relationship between Host & Contractors • OSHA 1910.147: – “On-site employer and outside employer shall inform each other of their respective lockout or tagout procedures”. – “On-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer’s energy control program”. • NFPA 70E 110.5: – Host employer must inform outside personnel of known hazards and information about installation. – Contract employer must ensure that his/her employees are trained in the hazards and follow host employer safety rules. SM
  35. 35. Group Lockout/Tagout OSHA 1910.147(f)(3)(i) “When servicing or maintenance is performed by a crew, craft, department or other group, they shall utilize a procedure which affords the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device” ONE authorized employee is responsible for overall procedure in the crew. If multiple crews are involved, there must still be an overall authorized employee responsible. Group Lockout devices such as Group Lockboxes and/or hasps must be used. SM
  36. 36. Shift or Personnel Changes • “Ensure continuity of lockout or tagout protection” • Employee from incoming shift MUST apply his/her lockout device before employee from outgoing shift removes his/her device. • Communicate about the work that has been done SM
  37. 37. Unavailable Employee • If authorized employee is not available to remove his device, then the employer may remove it IF: – Employer has procedures and training for such removal in energy control program – Verification that authorized employee is not at the facility – Making all reasonable efforts to contact authorized employee to inform him/her that lockout device has been removed – Ensuring that authorized employee is aware that his device was removed before resuming work at that facility SM
  38. 38. How to establish an energy control program? SM
  39. 39. The whole process SM
  40. 40. 1. Assessment Conduct a hazard assessment by identifying all equipment that is used, serviced, maintained or stored SM
  41. 41. 2. Procedures Determine Lockout/Tagout requirements for all equipment, identifying and documenting all energy sources – and create machine- specific procedures containing:  Type of Hazard  Location on the equipment  Proper isolation and lockout device/procedure  How to dissipate the stored energy  How to verify the isolation After this step, you should have an energy control program for your facility and machine-specific procedures SM
  42. 42. 3. Devices Circuit Breakers Electric Plug Toggle Switch Rocker Switch Cable Lockout Pneumatic Ball valve Gate Valve Group Lock Box Tags LOTO Stations LOTO Kits Hasps Padlocks Other SM
  43. 43. 4. Training A. Train all employees in facility  Authorized employees: • Recognition of applicable hazardous energy sources • Type and magnitude of energy available in the workplace • Methods and means necessary for energy isolation and control • Ways to verify that the energy isolation is effective  Affected and Other employees: • Instruction in the purpose and use of energy control procedure • Should never attempt to restart or re-energize machines or equipment which are locked out or tagged out • Respect use of warning tags B. Document the training SM
  44. 44. 5. Processes Processes need to be put in place to maintain the comprehensive program for the following:  Periodic Inspections must take place at least annually to identify and correct any deviations or inadequacies.  Retraining must take place anytime there is a change in responsibilities, equipment or procedures along with new employees SM
  45. 45. In conclusion… SM
  46. 46. Key Take-Aways for LOTO 1. Only work on equipment “hot” or “live” if it absolutely unavoidable 2. Lockout over Tagout 3. Facility specific and machine specific 4. Don’t forget about secondary energy sources or stored energy 5. Use annual inspections, regular training (annually suggested), and discipline to avoid complacency 6. Lockout/Tagout is only one part of a complete and effective safety program (safety ID, PPE, etc.) SM
  47. 47. 40 Words for Safety Plan Every Job Anticipate Unexpected Events Identify The Hazard Minimize the Hazard Use Procedures as Tools Use the Correct Tools for the Job Task Use Personal Protective Equipment Isolate the Equipment Assess People’s Abilities Protect the Person Audit these Principles SM
  48. 48. References  OSHA 1910 & 1926  NFPA 70E (2009)  NEC 2008  www.osha.gov  www.nfpa.org  Your company Lockout/Tagout procedure SM