Responding is Todd Morrison, product manager, Master Lock Co., Oak Creek, WI.
Answer: OSHA regulation 1910.147 – the control of hazardous energy (lockout/tagout) – is clear. It requires separate lockout/tagout energy control procedures for individual machines that have variable conditions for shutdown, such as multiple energy sources (electrical, water, gas and steam), different power connections (circuit breaker, valve and plugs) or control procedures. This applies to production equipment, pumps, boilers, air handler units, hot water heaters … you name it.
Simply buying lockout devices is not enough. “Procedures” in many facilities fall far short of enabling fast, efficient lockout/tagout action by employees. Numerous firms have general instructions, not machine-specific, or they may have lengthy documents that demand close review. Also, those documents may not be handy or located at the machine itself.
Using easy-to-implement procedures can pay by avoiding injuries, damaged equipment or OSHA citations, and by reducing time spent on lockout/tagout and machine maintenance, with increased equipment uptime and output.
Today, more companies use “procedural training” signs mounted on or near equipment, which focus on three key items a worker needs to know:
1. All energy sources on the machine that must be locked out
2. The location of each lockout point
3. The device needed to perform the lockout
Photos of lockout points around the machine show workers what to look for. Step-by-step actions on a chart provide an easy checklist to ensure no energy sources are overlooked, including stored-up potential energy. Some visual procedures also refer to lockout-point ID tags on the equipment, further simplifying locating each lockout point.
The idea is to enable someone not familiar with a machine to quickly and clearly grasp what needs to be done to safely accomplish the task.
Procedural training signs and ID tags need to withstand chemicals, dirt and grime; not scratch or tear; and be ultraviolet-resistant so they will not fade. Many signs are laminated. Better yet, on some signs, information is fused into the plastic material, making them virtually indestructible and easy to maintain.
Numerous sources, from safety consultants to lockout product companies, can help develop your program. Determine up front exactly what the service includes. Some consultants only write procedures; other providers take you from A to Z. Regardless, to fully implement a program, someone must:
• Audit all equipment and lockout points
• Write procedures
• Obtain management approval
• Produce procedural signs and training materials
• Install procedural signs and machine ID markers
• Procure lockout devices and padlocks
• Compile a manual of all procedures
• Train employees on the new lockout procedures
Look for consulting services that provide procedures in non-proprietary software and, more important, are backward and forward compatible, so you can later update your program without buying custom software. Some procedure manuals include a CD, so you can begin updating information for new or existing machines immediately.
Bottom line: Machine-specific OSHA compliance is required. If done well, it will pay off for you. Visual, easy-to-follow procedures lead to keeping employees safe and can simplify, expedite and improve safety in your facility for years to come while saving money in the long run.
Editor’s Note: This article represents the independent view of the author and should not be construed as a National Safety Council endorsement.