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Sample Plans Help Companies Keep Track of LOTO

LOTO is necessary for electrical, mechanical, hydraulic, pneumatic, chemical, thermal and other types of equipment that can produce hazardous energy. © getti – stock.adobe.com

By: Maureen Paraventi

Approximately three million workers in the U.S. use or service equipment that may unexpectedly release hazardous energy if that energy is not properly controlled. The results can be life altering or life ending:  electrocution, burns, crushing, cutting, lacerating, amputations or fractures. According to OSHA, workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation. Among those who are potentially exposed to hazardous energy are machine operators, craft workers and laborers. The agency estimates that compliance with its lockout/tagout (LOTO) standard prevents an estimated 120 fatalities and 50,000 injuries each year.[1]

The lockout of LOTO is the placement of a lockout device to ensure that equipment cannot be operated until the lockout device is removed. The tagout device that is the other part of the equation indicates that the equipment is being controlled may not be operated until the tagout device is removed.

LOTO procedures and devices are necessary for facilities that have electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other types of equipment that can produce hazardous energy. The steps companies take to de-energize machines and lock out sources of energy must be outlined in a program, per OSHA’s standard for The Control of Hazardous Energy (29 CFR 1910.147). The best LOTO program, according to the CDC’s National Occupational Research Agenda (NORA), is a written one. Fortunately, NORA offers sample written programs with different complexity levels. Once a company selects the one that is most appropriate, it can be customized to fit specific circumstances.

Sample Written Program A is comprehensive. It spells out management’s responsibilities, which include determining which applications require lockout and informing employees about them; instructing employees about the program, making copies available to all employees, periodically auditing the procedure to ensure compliance, posting machine-specific lockout and tagout instructions, enforcing the policy and utilizing disciplinary actions if the procedures are not followed. Employees, too, have requirements: to be aware of and follow the company’s hazardous energy control procedures and remind and encourage co-workers to follow them, as well. This sample written program addresses the roles of the safety coordinator, plant engineering or maintenance manager and contractors and other outside personnel in maintaining energized equipment safety. It details program elements such as the types of control devices that should be used (and the requirements they must meet); the kinds of labels they need to have (Do Not Start, Do Not Open, Do Not Close, Do Not Energize, and Do Not Operate); and the steps employees need to take when removing lockout or tagout devices. Shift and personnel changes, training, and periodic inspections and testing are all covered.

Managers will find a handy way to keep track of equipment types and identification numbers; hazardous energy sources (electrical, mechanical, etc.) and the location of the energy sources in the Hazardous Energy Identification Form that accompanies Sample Written Program A. There are also fields for authorized employees and procedures for shutting down equipment, applying and removing LOTO devices and verifying that all energy sources have been identified and properly locked out.

Sample Written Program B is a simplified, straightforward version that focuses on the basics. It explains the general rules for lockout, where lockout devices should be stored (in locked cabinets accessible to anyone who needs them) and what lockout procedures involve. It also covers training, inspections and shift and personnel changes. A Lockout and Tagout Inspection Form can help managers keep track of the type and location of machines that generate hazardous energy, the names of supervisors who conduct inspection and authorized employees who assist them, the inspection dates and any comments or recommendations. There is also a form for Machine-Specific Lockout Procedures.

Sample Written Program C provides a simple, three-point LOTO policy along with definitions of lockout, tagout, activation/energization, energy control procedures and hazardous motion and energy. The responsibilities of supervisors, employees and the safety leadership team are clearly delineated, as are LOTO procedures and employee training requirements. Inspection recordkeeping can be done with a Model Lockout And Tagout Inspection Form that has fields for the inspection date, name of inspector, and machine/equipment on which the energy control procedure was being utilized. Yes and No options allow companies to verify their compliance on whether or not employees received LOTO training and had access to adequate lock out/tag out devices and whether tagouts were legible and clearly displayed.

And finally, Brief Sample Written Program D includes management and “outside personnel” such as contractors. It has much of the information in the other written programs but gives special attention to the testing or positioning of machines, equipment or components when lockout or tagout devices must be temporarily removed from the energy isolating device. There is also a section on cord and plug-connected electrical equipment and quick disconnect air hoses.

The above descriptions are summaries. To determine if one of NORA’s sample written programs would be right for your company, you can download them at: www.cdc.gov/nora/councils/manuf/loto/guide/control.html WMHS

[1]www.osha.gov/sites/default/files/publications/OSHA3529.pdf

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