Lockout/Tagout



OSHA requires you to train employees to prevent lockout/tagout (LO/TO) accidents in the workplace (1910.147). This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy.

Employees must be trained in accordance with 1910.147(c)(7) . Here are 5 areas which are considered a must part of any Lockout/Tagout training program.

1. Failure to stop equipment. Sure, this sounds like common sense, but there’s much more involved. Some workers value productivity above safety and others feel that their age or experience with equipment make them immune from risk. “Taking the trouble” to properly safeguard energized equipment is essential in all cases.

2. Failure to disconnect from the power source. When working with and around electric equipment, some workers believe that simply operating the on/off switch will ensure their safety. They ignore the fact that the switch may be defective or that power may find its way through a short circuit or other source.

3. Failure to drain residual energy. There’s a reason that televisions carry warnings about trying to open the case even if the set is disconnected. That’s because many electrical devices store power in a capacitor or battery. Even unplugged, the risk remains. A compressed spring, hot pipe, pressurized tank, or heavy object hanging overhead can store energy even when the initial source of power is disconnected.

4. Accidental restart of machinery. Even if an employee knows how to shut down equipment before working on it, his or her co-workers may not. In too many instances, unknowing employees cause injury to their co-workers.

5. Failure to clear work areas before restarting. Restarting machinery must be performed as carefully as shutting it down and locking it out. A repair tool left in the works can fly out, or a restart while a co-worker remains in the path of danger represents as great a hazard as not locking out the machine at all.

Every employer has a responsibility to make sure all employees have a safe and stable work environment. These employees should have access to safety equipment and information at anytime they are on the jobsite. These employees should be able to go to their superiors with fears or concerns about safety without fear of termination or retaliation. In order to accommodate employees in such a fashion, we have compiled a short and condensed version of what an employer of the construction industry should have documented and in place for emergencies or for an OSHA inspection.

Management Commitment to Safety and Health

Employers and managers should lead by example. If your employee sees a superior taking safety seriously, they will too! Assign Safety and Health Responsibilities to employees. If you involve and rotate employee responsibilities, everyone will feel important and compliant. Give the assigned employees to correct minor issues. When a subordinate is give a little more power than their position requires, they are more likely to do what it takes to keep earning your trust and respect.

Assure your employees that they may voice their concerns regarding safety without any repercussions. These employees are the front line guys and they often see the danger in a position before a manager does. Listen to what they have to say and respect their position on safety. Most state laws protect whistleblowers, so check your states regulations. Inform employees of any hazards that you are aware of. Again, it is the employer’s responsibility to safeguard their employees, so keep the lines of communication open. If you are sharing a worksite with other companies or their employees, it is your responsibility to communicate any known hazards to them. Share a safe workplace. Post the OSHA state or Federal poster where all can see it. Employees have a right to know the law.

Hazard Identification and Determination

Carefully evaluate all operations, procedures, facilities, and equipment to identify hazards to employees and others. Monitor exposure levels of noise, air quality, heat, electricity, silica or dust, and moisture. Set aside time to do routine inspections. If you create a habit of safety awareness, you will create a timeless good habit. If you have an accident, conduct an investigation. The best way to prevent history from repeating itself it to identify and address the factors that caused the accident to begin with.

Do a PPE assessment. For every position within construction, evaluate the potential dangers associated with that assignment, then create a list of personal protection equipment that should be worn while performing these tasks. Determine if it goes beyond simple protection and what precautions should be taken. Document all of your findings.

Hazard Elimination and Control

Inspect and ensure all machines and tools are in proper working order with relevant standards. Develop positive practices with workplace safety and health so that it becomes second nature. Housekeeping is a must. Jobsites should be free of debris and cleaned up daily to ensure the safety of others.

Emergency Response Planning

Develop emergency response plans for your jobsite. If you are in an industry where your jobsite changes frequently, you still need to have a response plan. These do not have to elaborate, but clear enough to communicate what needs to be done in case of an emergency. Have an emergency route to evacuate injured employees. If your jobsite is in a new development area that the emergency response team may not have access too, have in a convenient location that is easily accessible by all employees. Use established landmarks and turn by turn directions. Have a list of all the jobsite emergency contact information including any pre-existing medical conditions and allergies that emergency personnel may need to know.

Training

Employers should train employees to recognize hazards and unsafe working conditions and how to avoid them. Employers need to provide training on safe work practices, safe operation of machinery, and equipment, and how to recognize when things are not safe. Access ladders, stairways, confined space, and enclosed space entry hazards are all subjects that need to be trained and documented.

Recordkeeping

You must record and post injuries and fatalities. This is otherwise known as the 300-log. Maintain medical records and exposure records for all employees and past employees. You must maintain all appropriate documents and tags for abatement purposes. If you do not have these items, it could mean hefty fines.

Here is part 2 of the Electrical Safety Quiz.  The answers will be posted next.

11. Exposed energized parts:
    a. Are enclosed
    b. Are capable of being accidentally approached nearer than a safe distance
    c. Are usually insulated
    d. Are always guarded

12. Exposed parts are considered to be energized:
    a. If they are not locked/tagged out
    b. If they are insulated
    c. If they are locked/tagged out
    d. If you can’t see that they are disconnected

13. A qualified person:
    a. Is automatically considered to be qualified to work on all electrical equipment
    b. Must be a licensed electrician
    c. Is familiar with the construction and operation of the equipment and the hazards involved
    d. All of the above

14. Lockout/tagout:
    a. Must be done by a qualified person
    b. Can be done by an unqualified person
    c. Must be done by a supervisor
    d. Can be done by anyone

15. If you are working under unguarded, energized overhead lines:
    a. The clearance distance is 10 feet for voltages of 50 kv or less to ground
    b. The clearance distance is 10 feet plus 4 inches for every 10 kv greater than 50 kv to ground
    c. The clearance distance is always 10 feet
    d. Both a. and b

16. When a vehicle is intentionally grounded because its elevated parts could possibly come into contact with energized overhead lines:
    a. An employee must stand near the grounding location to warn other people to stay away
    b. A qualified employee must stand near the grounding location to warn other people to stay away
    c. No one is allowed to stand near the grounding location
    d. The grounding location must be locked/tagged out

17. Portable cord- and plug-connected equipment:
    a. Must be inspected before use on every shift
    b. Should be inspected each morning
    c. Must be inspected annually by a licensed electrician
    d. Only needs an inspection if you notice a problem

18. When electrical hazard warning signs are posted and a barricade limits entry into an area:
    a. You must use the buddy system to enter the area
    b. A written entry permit must be posted near the space
    c. Non-qualified persons need special permission before they work in the area
    d. The area contains exposed energized parts

19. If you need to use a ladder while working near electrical parts:
    a. Use a conductive ladder
    b. Use a metal ladder
    c. Use a non-conductive ladder
    d. The ladder must be intentionally grounded

20. If a circuit breaker trips and deenergizes the machine you are using:
    a. You can just manually re-set the circuit breaker and continue to use the machine
    b. It must be determined that it would be safe to reenergize the circuit before the circuit breaker can be re-set
    c. You must immediately lock out the machine
    d. You must install a new circuit breaker

 

A typical day in the life of the EH&S manager might go something like this:


Get in the office at 7 AM and go over all the previous days reports about any incident(s) that occurred.  Next you get that cup of coffee to spill over all those reports.  Now you check out the 50 or so E-mails of which at least 30 require a response.  Now it is time to walk the facility and do a short audit to make sure the people are wearing their PPE.  Go back and check more e-mails, and go over the budget for this month.  It’s 9AM and time for your first managers meeting of the day.  You report on 1 incident and what is happening to the employee.  Now back to the office to write your agenda for the weekly safety meeting and go over the OSHA 300 log.  After a short break you need to go over training records to see who needs what training and when can you get it done. Time to start designing a hazardous materials training class for new employeesas some of your MSDS sheets have changed.  Lunch, and then back to designing the training class you use to outsource, but not in this year’s budget.   Call coming in from the floor about a machine-guarding problem (no one hurt).  Have to go on the floor with maintenance to check the machine (lockout/tagout), they need it running for the production line.  Another call on the Nextel that employee requires minor first aid.  Go back to the office to call supervisors to schedule training, but hey are NOT happy to have to take people away from production.  Your boss calls and wants a report about safety to give to his/her boss.  Day almost over, you go back and check on machine to make sure it is properly guarded and find some flammable hazardous materials left out unattended.  Talk with supervisors about this and how to put them away correctly. 5:30PM, time to leave the building, but have to keep Nextel on just in case.  Oh no, I forgot to get the safety meeting agenda put together, well tomorrow is another day.

Here is who I was today:

  • A manager
  • An IT person
  • Asafety person
  • Administrative assistant
  • A finance person
  • An instructional designer
  • A maintenance person
  • A medic
  • An arbitrator
  • An employee
  • Oh Ya! a family person too!!!


So what do you think, sound something like your day?  How many other jobs do you do that I left out?  Send a comment and we will compile a complete (as possible) of all the jobs a safety manager has to do.  Let’s hear from you.
    

 

Training Class.pngRequirements for employers to train employees exist throughout U.S. OSHA standards. However, some employers and, apparently, some OSHA inspectors, are not aware that training must be conducted in a manner that the employee can understand.

OSHA’s general policy is that if an employee receives job instructions in a language other than English, training and information must also be conveyed in that language. Similarly, says OSHA, if the employee’s vocabulary is limited, the training must account for that limitation. Furthermore, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.

“As a general matter, employers are expected to realize that if they customarily need to communicate work instruction or other workplace information to employees at a certain vocabulary level or in a language other than English, they will also need to provide safety and health training to employees in the same manner,” says OSHA.

OSHA adds that its training provisions contain a variety of specific requirements to ensure that employees are comprehending instruction. For example, standards covering lockout/tagout, respiratory protection, and bloodborne pathogens each require that employers take measures to ascertain the level to which the employee has comprehended the safety provisions.

In its instructions to inspectors, OSHA states, “If a reasonable person would conclude that the employer had not conveyed the training to its employees in a manner they were capable of understanding, then the violation may be cited as serious.”