The Occupational Health and Safety Administration (OSHA) has several additional requirements for the enforcement of lockout/tagout, which can be found inside section 1910.147 of the Federal Register (The Control of Hazardous Energy (lockout/tagout).
It is important that these requirements are followed at all times just like the rest of the documentation found within this section. Not doing so can incur severe criminal and financial penalties, as well as severely affect the safety of employees working on maintenance.
Temporary Lockout Removal
The first procedure outlined under additional requirements involves the removal of lockout devices temporarily, and to do so, OSHA states:
“In situations in which lockout or tagout devices must be temporarily removed from the energy isolating device and the machine or equipment energized to test or position the machine, equipment or component thereof, the following sequence of actions shall be followed:” (Section F, 1)
Step 1: Clearance
OSHA states that you must:
“Clear the machine or equipment of tools and materials in accordance with paragraph (E, 1) of this section.” (Section F, 1, I)
By doing this, you ensure that materials used during maintenance cannot impact the functions of the machinery, as leaving them inside could cause catastrophic damage to equipment integrity, and also could create a massive hazard.
Step 2: Employee Accounting
“Remove employees from the machine or equipment area in accordance with paragraph (E, 2) of this section.” (Section F, 1, II)
Before machines can be reactivated you must make sure that all employees, whether involved with the lockout/tagout procedure or not, are moved away from the area where the machine/equipment is and that all of the employees are accounted for.
Doing this ensures nobody is left behind working on the machine, which could have extreme results were they to still be working on the machinery when it becomes reactivated.
Step 3: Lockout Removal
“Remove the lockout devices as specified in paragraph (E, 3) of this section;” (Section F, 1, III)
Once employees and equipment are removed from the relevant area(s), the responsible person who attached the lockout can then go about removing the lockout device(s).
Step 4: Energisation
“Energize and process with testing or positioning;” (Section F, 1, IV)
Now that all hazards, employees and anything else have been removed, accounted for and catalogued, the energy source can then be switched back on and utilised for the purposes needed.
Step 5: Reapply Lockout Procedure
“Deenergize all systems and reapply energy control measure in accordance with paragraph (d) of this section to continue the servicing and/or maintenance.” (Section F, 1, V)
Once any temporary removal work has been officially completed, the full scope of a lockout procedure must be reapplied in order to once again correctly isolate energy source(s).
Every step previously used must be repeated to ensure that full compliance is met during the lockout procedure, and employers must ensure that employees are being as rigorous as possible when preparing for lockout procedures.
Outside Personnel/Contractors etc.
There are a few rules and regulations enforced by OSHA which govern the prospect of using outside sources for a lockout tagout procedure. The first of these states:
“Whenever outside servicing personnel are to be engaged in activities covered by the scope and application of this standard, the on-site employer and the outside employer shall inform each of their respective lockout or tagout procedures.” (Section F, 2, I)
And:
“The 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.” (Section F, 2, II)
In other words, outside contractors and other members are required to adhere to the energy control program of the organisation where work is to be carried out.
Group Lockout/Tagout
Often there are times when carrying out LOTO procedures that the use of a team of employees is used to perform lockout, and this is often recommended for extra security as each team member can attach padlocks to a lockout device and be responsible for their own lock.
Like everything else under lockout/tagout, this section contains several OSHA regulations and states firstly that:
“When servicing and/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.” (Section F, 3, I)
In other words, the group lockout situation must follow a strict set of guidelines to do this, or as OSHA puts it:
“Group lockout or tagout devices shall be used in accordance with the procedures required by paragraph (C, 4) of this section including, but not necessarily limited to, the following specific requirements: (Section F, 3, II)
Responsibility
“Primary responsibility is vested in an authorized employee for a set number of employees working under the protection of a group lockout or tagout device (such as an operations lock);” (Section F, 3, II, A)
In other words, even though this is a group lockout situation, there should be one person who is in charge of the whole process, and they have the responsibility for ensuring the safety of all the other employees. It is this person’s responsibility to make sure all employees are constantly accounted for and to oversee the correct implementation of an organisation’s lockout/tagout program.
Section B states the following are requirements:
“Provision for the authorized employee to ascertain the exposure status of individual group members with regard to the lockout or tagout of the machine of equipment and”
Section C states:
“When more than one crew, craft department, etc. is involved, assignment of overall job-associated lockout or tagout control responsibility to an authorised employee designated to coordinate affected work forces and ensure the continuity of protection;”
In other words, one designated has complete responsibility for the team, and it their job to enforce, regulated and ensure that the energy control program is followed correctly and ensure the constant safety of his/her team.
Locking Out
“Each authorised employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being services or maintained.” (Section F, 3, II, D)
In other words, this means that every employee involved in a group lockout situation attaches their own form of lockout to the energy source. This is usually done by means of a padlock, and these can be colour co-ordinated to help with identification purposes. It is then the responsibility of the person who attached the lock to remove it after the work has been completed, and doing this ensures that each team member has been fully accounted for before any re-activation can be applied to the energy source.
Shift/Personnel Changes
The final section of OSHA’s guidelines is related to the change of employees between designated time slots, and it is important for employers to be aware of the following regulation when this is taking place.
“Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of lockout or tagout protection, including provision for the orderly transfer of lockout or tagout device protection between off-going and oncoming employees to mimize exposure to hazards from the unexpected Energisation or start-up of the machine or equipment, or the release of stored energy.” (Section F, 4).
