Review of Lockout / Tagout / Blockout Procedures

Review of lockout / tagout / blockout procedures

By Steve Sayer?on 1/11/2016 Revised: 09/25/22

MEATINGPLACE.COM

Steve Sayer is a 41-year veteran of the beef / poultry industry and a food safety / FDA / OSHA / Humane Handling and GFSI consultant representing Sayer Consulting / Auditing, LLC (San Clemente, Calif.) Reach him [email protected].

General Overview

Failure to comply with the lockout/tagout standard is listed as one of fed OSHA’s top 10 most frequently cited standards year after year. Workers injured on the job from exposure to hazardous energy lose an average of 24 days of work to recuperation.

Looking at the 328 electrical occupation fatalities that occurred between 2011 and 2019, lockout / tagout / blockout (LOTOBO) procedure malfunction was the cause in 44 cases, or 13.4%. This was the third leading cause of electrical occupation fatalities.

The first leading cause was listed as other (98 cases or 29.9%), while the second cause was misjudgment of a hazardous situation (89 cases or 27.1%).

Insufficient / lack of protective work clothing / equipment (29 cases or 8.8%),

Malfunction in securing / warning operation (12 cases or 3.7%),

Safety devices removed/inoperable (10 cases or 3%),

Equipment inappropriate for operation (10 cases or 3%),

Material handing procedure inappropriate (nine cases or 2.7%),

Insufficient/lack/written work practice program (nine cases or 2.7%),

Position inappropriate for task (seven cases or 2.1%),

Insufficient / lack / engineering controls (seven cases or 2.1%),

Perception malfunction, task / environment (three cases or 0.9% of cases),

And defective equipment in use (one case or 0.3%) accounted for the source of the remaining fatalities.

OSHA’s standard for the control of hazardous energy --?29 CFR Part 1910.147?-- exclusively addresses the practices and procedures that are necessary to disable machinery and equipment to preclude the release of hazardous energy while trained / documented employees or contractors perform servicing / maintenance activities.

OSHA’s database evinces that lack of proper lockout / tagout / blockout (LOTOBO) procedures in the general ##?food industry?resulted in ##28 fatalities and ##227 serious injuries between 2003 and 2013.?

It’s estimated, as depicted within the penultimate picture scan above, that compliance to OSHA’s LOTOBO standard prevents 120 deaths and 50,000 injuries annually.

Depending upon the discretion of the USDA / FSIS Inspector - In - Charge, LOTOBO of equipment and machinery SHALL be performed by the establishment prior to pre-operational inspection.

10 Procedures To Know By Rote

Energy Control Program (ECP) 1910.147(c)(1)

The employer SHALL establish a program of energy control procedures, employee training and periodic inspections to ensure that before any employee/contractor performs any servicing on a machine or equipment, where the unexpected energizing, start-up or release of stored energy could occur and cause injury, the machine/equipment is isolated from the energy source and rendered inoperative.

Energy Hazards

• Electricity
• Hydraulic pressure?
• Hydraulic accumulation
• Pneumatic
• Gas
• Steam
• Thermal
• Gravity
• Kinetic spring tension
• Fluids

Energy Control Procedures – 1910.147(c)(4)

These procedures SHALL specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy; including the means to enforce compliance.

Protective Materials / Hardware – 1910.147(c)(5)

LOTOBO devices SHALL be standardized (color, shape, size) and personalized to each person and used exclusively for LOTOBO. Lockout devices SHALL be substantial to prevent removal without excessive force. Tagout devices and their attachment must / SHALL be substantial to prevent accidental removal of 50 pounds minimum unlocking strength, while warning of hazardous conditions.

Inspections - 1910.147(c)(6)

Employers SHALL conduct periodic inspection of their energy control procedure at least annually to ensure that the procedures and requirements of OSHA are being realized.

• The periodic inspection SHALL be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected.
• The periodic inspection SHALL be conducted to correct deviations/inadequacies identified.
• Where lockout is used for energy control, the periodic inspection SHALL include a review between the inspector and each authorized employee, of that employee’s responsibilities under the energy control procedure being inspected.
• Where tagout is used for energy control, the periodic inspection SHALL include a review between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure.
• The employer SHALL certify inspections have been performed. The certification SHALL identify the specific machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person(s) performing the inspections.

Employee Training – 1910.147(c)(7)

The employer SHALL provide training to ensure that the purpose and function of the ECP are understood by employees and that the knowledge/skills required for the safe application, usage and removal of the energy controls are employed by employees.

• Each authorized employee receives training in the recognition of applicable hazardous energy sources, type and magnitude of the energy available in the workplace, and the methods / means necessary for energy isolation and control.
• Each affected employee SHALL be instructed in the purpose and use of energy control procedure(s).
• All other employees whose work operations are or may be in an area control procedures are utilized, SHALL be instructed about the procedure, and the prohibition relating to attempts to restart / reenergize machines or equipment which are locked or tagged out.

When tagout systems are used, employees SHALL be trained in the following limitation of tags:

• Tags are essentially warning devices affixed to energy isolating devices and do not provide the physical restraint on those devices that’s provided by a lock.
• When a tag is attached to an energy isolating means, it’s SHALL NOT be removed without authorization of the authorized person(s) responsible for it: It’s never to be ignored, bypassed nor defeated.
• Tags must / SHALL be legible/understandable by all authorized/affected employees and all other employees whose work operations may be in the area for effectiveness.
• Tags and their means of attachment must / SHALL be made of material that withstands the environmental conditions encountered at the workplace.
• Tags must / SHALL be securely attached to energy isolating device(s) so they cannot be inadvertently/accidentally detached during use.

Retraining – 1910.147(c)(7)(iii)

Retraining SHALL be provided for all authorized and effected employees whenever there is a change in job assignments, change in machines, equipment or processes that present a new hazard, and when there is a change in the energy control procedures.

The employer SHALL certify that employee training has been accomplished and is kept current. The certification SHALL contain each employee’s name and dates of training and re-training.

Application of Control – 1910.147(d) and Release – 1910.147(e)

Before an authorized or affected employee shuts off a machine or equipment, the authorized employee SHALL have knowledge of the type and magnitude of the energy, the hazards of energy to be controlled and the method / means to control energy.

• The machine / equipment SHALL be turned off or shut down using the procedures established for the machine / equipment.
• All energy isolating devices needed to control the energy SHALL be physically located in such a manner as to isolate the machine/equipment from all energy sources.
• Lockout or tagout devices SHALL be affixed to each energy-isolating device by authorized employees.
• Tagout devices SHALL be affixed that SHALL clearly indicate that operation or movement of energy isolating devices from the safe or off position is prohibited.
• Where tagout devices are used with energy isolating devices, the tag attachment SHALL be fastened at the same point that the lock would have been attached.
• If a tag cannot be affixed directly to the isolating device, the tag SHALL be located as closely as possible to the device so it is in a position “obvious” to anyone.
• Following the application of a LOTOBO, all potentially hazardous stored or residual energy SHALL be relieved, disconnected, restrained and rendered safe.
• If there is possibility of re-accumulation of hazardous energy, verification of isolation SHALL be continued until servicing is completed or the accumulation no longer exists.
• Prior to starting work that’s been LOTOBO, the authorized employee SHALL verify that isolation and de-energization has been accomplished.

Before LOTOBO devices are removed and energy is restored to the machine or equipment, procedures SHALL be followed by the authorized employee(s):

• Work area SHALL be inspected to ensure nonessential items have been removed and the components are operationally intact.
• Work area SHALL BE checked to ensure all employees are safely positioned.
• After the LOTOBO devices are removed and before a machine / equipment is started, affected employee(s) SHALL be notified that the LOTOBO device(s) have been removed.
• Each LOTOBO device SHALL be removed from each energy-isolating device by the employee whole applied the device.?(Exception: when the authorized employee who applied the LOTOBO device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures / training has been developed and is included within the employer’s program.?This can only be done when the authorized employee is not at the facility; reasonable efforts were made to contact the person; and the authorized employee SHALL BE informed VIA TEXT AND when resuming work at the facility.)

Outside Contractors – 1910.147(f)(2)

When outside contractors (including USDA inspectors before, during, and / or after production), are engaged in activities covered by the scope of this standard, the on-site employer and contractor SHALL inform each other of their LOTOBO procedures. The on-site employer SHALL ensure that their employees understand and comply fully with the restrictions / prohibitions of the contractors ECP.

Know that if an outside contractor is seriously hurt while present at your facility, OSHA SHALL audit your company and that of the hired contractor.

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I (subjectively) have an awesome / detailed - oriented 'OSHA Maintenance Program for Contractors,' that I've updated over the years - that is fully applicable to the food and beverage sectors - that nails GFSI and beyond - Square On.

I plan on chopping it up and making them into LinkedIn Blogs.

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Group LOTOBO 1910.147(f)(3)?

When servicing / maintenance is performed by a group, a procedure which affords the employees a level of protection equivalent to that provided by the implementation of a personal LOTOBO device SHALL be utilized.

Group LOTOBO devices SHALL be used in accordance with the procedures required by section?1910.147(c)(4)?but isn’t limited to the following:

• Primary responsibility is vested in an authorized employee for a set number of employees working under the protection of a group LOTOBO device.
• Provisions for the authorized employee to ascertain the exposure status of individual group members with regard to the LOTOBO of the machine or equipment.
• When more than one department is involved, overall job-associated LOTOBO responsibilities SHALL be assigned to an authorized employee designated to coordinate affected work forces and ensure continuity; and - each authorized employee SHALL affix a personal lockout or tagout device to the group lockout device, group lockbox or comparable mechanism when one begins work and remove those devices when one stops working on the machine or equipment.?

Shift Or Personnel Changes – 1910.147(f)(4)

Specific procedures SHALL be utilized during shift or personnel changes to ensure the continuity of LOTOBO protection, including provision for the orderly transfer of LOTOBO device protection between ingoing and outgoing employees to minimize exposure to hazards from the unexpected energization or start-up of the machine/equipment – including the release of stored (springs, residual pressure, etc.) energy.

When time permits, tap into?YouTube?that features an eclectic selection of LOTOBO videos that can be used as training aids as well as a source of information that can complement your existing LOTOBO program.

The short to the point YouTube video (Block The Shock) mentioned / highlighted directly above - is one of the best I've seen.

BLOCK - THE - SHOCK

XTRA XTRA XTRA

Who needs to worry about LOTOBO if - - - Tip Top Management is 110% behind it?

And well they should be.

I wrote / customized companies only ROBUST LOTOBO programs - nothing less.

ROBUST LOTOBO protocols has saved lives and most importantly --- kept families together as originally intended.

I must admit that I lost a very close buddy from High School due to the lack of proper LOTOBO. Perhaps I'm too nostalgic, I suppose.

LOTOBO not only saves lives for families - as previously mentioned - but close High School Buddies 2.

Trust me.

RIP Richard E. Stone Jr., Class of 1974 AD.

Victor Elementary School (3rd Grade to 8th Grade) and West Torrance High School (1970 - 1974), California, USA.

Teammates - 6th, 7th and 8th Grade Victor Colts Basketball Team. Played half-time at the Inglewood, Forum - - - Los Angeles Lakers (Jerry West / Wilt Chamberlain) vs Milwaukee Bucks (Kareem Abdul - Jabbar and Oscar Robertson) way back in 1969.

Teammates - C's, B's, Junior Varsity and Varsity Basketball - West Torrance High Warrior Teams.

WORD OF THE DAY

ECLECTIC

In philosophy there has been a remarkable increase of activity, partly assimilative or?eclectic?and partly original.

SPECIAL SPECIAL MENTION:

William Chester Minor?(22 Jun. 22,1834 – Mar. 25, 1920), was an American army surgeon, psychiatric-hospital patient, and - - - lexicographical researcher.

After serving in the Union Army during the Great?American Civil War, Minor moved to England. Affected by?delusions, he shot a man who he believed had broken into his room, and was consequently committed from 1872 to 1910 to a secure British psychiatric hospital.

While incarcerated, Minor became an important contributor to the genesis of?Oxford English Dictionary. He was one of the project's most effective volunteers, reading through his large personal library of antiquarian books and compiling quotations that illustrated how particular words were used.

In 1910, responding to protests about Minor's treatment,?Winston Churchill, then British?Home Secretary, ordered Minor deported to the United States.

Minor was hospitalized in Connecticut, where he died in 1920.

Wow.

The Professor And The Mad Man is included in the upcoming Book Review Blog for Fall / Winter 2022.

Simon Winchester, a British author of numerous fascinating / well-researched / eclectic books, is an awarding winning writer of Historical Non-Fiction.

Simon Winchester is others, with myself included, favorite writer of Historical Non-Fiction from the 20th century and beyond.

{Save "The Day The World Exploded - Krakatoa (2003)" by Simon Winchester for your next South Pacific excursion.}