This training presentation targeted at Contractors and Electricians covers the importance of Lockout/Tagout as a form of mitigation, the necessary elements of an effective program for the control of hazardous energy along with the means of handling special cases within the program.
2. Agenda
• Why is Lockout/Tagout (LOTO) important?
• How does LOTO apply to contractors?
• What is required for compliance?
• How to establish an energy control
program?
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5. Employee Safety
• Approximately 3 million workers in the US service
equipment and face the greatest risk of injury if
Lockout/Tagout is not properly implemented
• Lockout/Tagout prevents an estimated 120
fatalities and 50,000 injuries each year in the US.
• Workers injured from exposure to hazardous
energy lose an average of 24 workdays for
recuperation
Source: http://www.osha.gov/SLTC/controlhazardousenergy/index.html
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6. Legal Risk
• Created under the Occupational Safety and Health Act of 1970
• Only government regulatory agency for workplace safety
• Instructs, conducts inspections and enforces workplace safety
• Does not apply to government facilities
OSHA General Duty Clause States:
“Each employer shall furnish to each of his employees employment and a
place of employment which are free from recognized hazards that are
causing or are likely to cause death or serious physical harm to his
employees.”
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7. State Plans
• Twenty-four states, Puerto Rico
and the Virgin Islands have
OSHA-approved State Plans
• Job safety and health standards
must be "at least as effective as"
comparable federal standards.
• Most States adopt standards
identical to federal ones -- States
have the option to promulgate
standards covering hazards not
addressed by federal standards.
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8. Legal Risk
OSHA Standards
• Required by law for employers to follow
• Requirements in General Terms
• Lots of details but also rely on consensus industry standards for guidelines
NFPA 70E – 2009 (Originated 1976)
• Details – safe installation, maintenance and work practices, signs, PPE
(Personal Protective Equipment), shock hazard and AF analysis…
• Only applies to electrical energy (Electrically Safe Working Condition)
FINAL RULE 72:7135-7221 in Aug 2007:
“The Occupational Safety and Health Administration (OSHA) is revising the general
industry electrical installation standard found in Subpart S of 29 CFR Part 1910. The
Agency has determined that electrical hazards in the workplace pose a significant risk of
injury or death to employees, and that the requirements in the revised standard, which
draw heavily from the 2000 edition of the National Fire Protection Association's
(NFPA) Electrical Safety Requirements for Employee Workplaces (NFPA 70E), and the
2002 edition of the National Electrical Code (NEC) , are reasonably necessary to
provide protection from these hazards.
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9. Legal Risk
OSHA Standard 29 CFR 1910.147:
• Adopted in 1989
• Applies to general industry
employment
• Covers about 39 million workers
• Established minimum performance
requirements for the control of
hazardous energy
• Covers the servicing and maintenance
of machines and equipment in which
the unexpected start-up or the
release of stored energy could cause
injury
• Applies to all types of energy:
mechanical, hydraulic, electrical, gas,
pneumatic, water, chemical, thermal,
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etc…
10. Legal Risk
NFPA 70E – Chapter 1 Article 110 States:
“covers electrical safety-related work practices and
procedures for employees who work on or near exposed
energized electrical conductors or circuit parts in
workplaces that are included in the scope of this standard”
“Intended to provide for employee safety relative to
electrical hazards in the workplace”
Source: NFPA Regulations – Chapter 1, Article 110, 2009
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12. Financial Risk
Downtime
• Personnel
• Equipment
Legal Action
• Liability and Injury
• Cost of outside counsel
Fines and Penalties:
• LOTO is #3 most cited by OSHA
• Fiscal Year 2006
38,579 federal OSHA site inspections
58,058 state OSHA site inspections
Source: Occupational Hazards, February 2008
3,659 violations for LOTO totaling about $6M
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14. Risk Mitigation
Conclusion:
“The costs in terms of human suffering,
lost productivity, worker’s
compensation claims and lawsuits can
far outweigh the investment in a
comprehensive program.”
Source: Occupational Health&Safety Volume 76, Number 10
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17. Lockout/Tagout
• 1926.417 is very brief
• 1926.21 mandates training to avoid unsafe conditions
• 1910.147 provides LOTO best practices even though it does not
directly apply to Construction Industry.
• 1910.333 (Selection and use of work practices) provides additional
best practices for safely dealing with electrical energy.
• OSHA General Duty Clause
• When do you fall under 1910 versus 1926?
In the end, proper Lockout/Tagout is for your safety!
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19. Elements of a Lockout/Tagout program
Procedures
Training
Device requirements
Inspections
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20. Procedures
OSHA 1910.147(c)(4)(i)
“Procedures shall be developed, documented and utilized
for the control of potentially hazardous energy when
employees are engaged in the activities covered by this
section”
NFPA 70E 120.2 (F) / Ch. 5-4
“The employer shall maintain a copy of the procedures
required by this section and shall make procedures
available to all employees”
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21. Procedures
Procedures shall be developed, documented
and utilized for the control of potentially
hazardous energy:
– Steps to de-energize and re-energize
– Lockout/Tagout devices to utilize
– Drawings/diagrams (equipment specific)
– What employees are exposed to hazards?
– Who is qualified to perform LOTO?
– Who is in charge of the LOTO program?
Standards/Codes: OSHA 1910.147(c)(4); NFPA 70E - Article 120.2 (D) & (F), and Annex G
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22. Procedures
Steps for equipment shutdown
1. Prepare for and announce shutdown
2. Shutdown equipment
3. Disconnect energy sources / test for isolation
4. Lockout and/or Tagout
5. Release stored energy
6. Verify isolation
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23. Procedures
Steps for equipment startup
1. Verify equipment operationally intact - Clear all
personnel and tools
2. Ensure employees are safely positioned
3. Remove lockout/tagout devices from each
energy-isolating device
4. Notify all affected employees of Lockout/Tagout
removal and that work has been completed
5. Start equipment
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24. Training
OSHA 1910.147(c)(7)(i)
“The employer shall provide training to ensure that the purpose and
function of the energy control program are understood by
employees and that the knowledge and skills required for the safe
application, usage, and removal of the energy controls are
acquired by employees”
NFPA 70E 120.2 (B) (2)
“Each employer shall provide training as required to ensure
employees’ understanding of the lockout/tagout procedure
content and their duty in executing such procedures”
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25. Training
Authorized employees – person who locks out or
tags out machines or equipment in order to perform
servicing or maintenance on that machine or
equipment
Affected employees – employee whose job requires
him/her to operate or use a machine or equipment
on which servicing or maintenance is being
performed under Lockout or Tagout, or whose job
requires him/her to work in an area in which such
servicing or maintenance is being performed
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26. Training
Authorized employees:
Recognition of applicable
hazardous energy sources
Type and magnitude of energy
available in the workplace
Methods and means necessary for
energy isolation and control
Ways to verify that the energy
isolation is effective
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27. Training
Affected employees:
Instructed in the purpose and
use of energy control procedure
Should never attempt to restart
or re-energize machines or
equipment which are locked out
or tagged out
Respect use of warning tags
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28. When Should a Company Retrain?
New employees, or change in
employee responsibilities
New equipment, or change in
machines, equipment or processes
that present a new hazard or change
to energy control procedures
Deviations from, or inadequacies in,
the employee’s knowledge or use of
the energy control procedure
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29. Device Requirements
OSHA 1910.147(c)(7)(i)
“Lockout device – a device that utilizes a positive means such as
a lock, either key or combination type, to hold an energy
isolating device in a safe position and prevent the energizing of
a machine or equipment”
NFPA 70E 120.2 (E) (2)
“Each employer shall supply, and employees shall use,
lockout/tagout devices and equipment necessary to execute
the requirements of 120.3(E). Locks and tags used for control
of exposure to electrical energy hazards shall be unique, shall
be readily identifiable as lockout/tagout devices, and shall be
used for no other purpose.”
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30. Device Requirements
Lockouts must be:
Used only to control energy
Durable enough for use in their environment
Standardized by either color, shape or size
Substantial – withstand all but excessive
force
Identify the employee applying the device
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31. Device Requirements
Tags must be:
Durable enough for use in their
environment
Substantial – enough to resist
accidental or inadvertent removal
Standardized by either color, shape
or size
Identify the employee responsible for
the Tagout
Non-reusable attachment device &
attachable by hand
Withstand 50 lbs of force
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32. Inspection
OSHA 1910.147(c)(6)(i)
“The employer shall conduct a periodic inspection of the energy
control procedure at least annually to ensure that the procedure
and the requirements of this standard are being followed.”
NFPA 70E 120.2 (C) (3)
“An audit shall be conducted at least annually by a qualified person
and shall cover at least one Lockout/Tagout in progress and the
procedure details. The audit shall be designed to correct
deficiencies in the procedure or in employee understanding.”
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33. Inspection
At least annually
Performed by authorized employee, other than the one(s)
using the energy control procedure
Cover Lockout/Tagout in progress
Between inspector and authorized/affected employees
• Lockout – review employees responsibilities under the
energy control procedure inspected
• Tagout – review employee responsibilities and Tagout
limitations
Document inspection
Correct any deviations or inadequacies identified
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34. Outside Personnel
• Relationship between Host & Contractors
• OSHA 1910.147:
– “On-site employer and outside employer shall
inform each other of their respective lockout or
tagout procedures”.
– “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”.
• NFPA 70E 110.5:
– Host employer must inform outside personnel of
known hazards and information about installation.
– Contract employer must ensure that his/her
employees are trained in the hazards and follow
host employer safety rules.
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35. Group Lockout/Tagout
OSHA 1910.147(f)(3)(i)
“When servicing 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”
ONE authorized employee is responsible
for overall procedure in the crew.
If multiple crews are involved, there must
still be an overall authorized employee
responsible.
Group Lockout devices such as Group
Lockboxes and/or hasps must be used.
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36. Shift or Personnel Changes
• “Ensure continuity of lockout or
tagout protection”
• Employee from incoming shift
MUST apply his/her lockout device
before employee from outgoing
shift removes his/her device.
• Communicate about the work that
has been done
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37. Unavailable Employee
• If authorized employee is not available to
remove his device, then the employer may
remove it IF:
– Employer has procedures and training for such
removal in energy control program
– Verification that authorized employee is not at
the facility
– Making all reasonable efforts to contact
authorized employee to inform him/her that
lockout device has been removed
– Ensuring that authorized employee is aware
that his device was removed before resuming
work at that facility
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40. 1. Assessment
Conduct a hazard
assessment by
identifying all equipment
that is used, serviced,
maintained or stored
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41. 2. Procedures
Determine Lockout/Tagout requirements for
all equipment, identifying and documenting
all energy sources – and create machine-
specific procedures containing:
Type of Hazard
Location on the equipment
Proper isolation and lockout
device/procedure
How to dissipate the stored
energy
How to verify the isolation
After this step, you should have an
energy control program for your facility
and machine-specific procedures
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42. 3. Devices
Circuit Breakers Electric Plug Toggle Switch Rocker Switch Cable Lockout
Pneumatic Ball valve Gate Valve Group Lock Box Tags
LOTO Stations LOTO Kits Hasps Padlocks Other
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43. 4. Training
A. Train all employees in facility
Authorized employees:
• Recognition of applicable hazardous energy
sources
• Type and magnitude of energy available in the
workplace
• Methods and means necessary for energy
isolation and control
• Ways to verify that the energy isolation is
effective
Affected and Other employees:
• Instruction in the purpose and use of energy
control procedure
• Should never attempt to restart or re-energize
machines or equipment which are locked out
or tagged out
• Respect use of warning tags
B. Document the training
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44. 5. Processes
Processes need to be put in place to
maintain the comprehensive
program for the following:
Periodic Inspections must take
place at least annually to
identify and correct any
deviations or inadequacies.
Retraining must take place
anytime there is a change in
responsibilities, equipment or
procedures along with new
employees
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46. Key Take-Aways for LOTO
1. Only work on equipment “hot” or “live” if it absolutely
unavoidable
2. Lockout over Tagout
3. Facility specific and machine specific
4. Don’t forget about secondary energy sources or stored energy
5. Use annual inspections, regular training (annually suggested),
and discipline to avoid complacency
6. Lockout/Tagout is only one part of a complete and effective
safety program (safety ID, PPE, etc.)
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47. 40 Words for Safety
Plan Every Job
Anticipate Unexpected Events
Identify The Hazard
Minimize the Hazard
Use Procedures as Tools
Use the Correct Tools for the Job Task
Use Personal Protective Equipment
Isolate the Equipment
Assess People’s Abilities
Protect the Person
Audit these Principles
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48. References
OSHA 1910 & 1926
NFPA 70E (2009)
NEC 2008
www.osha.gov
www.nfpa.org
Your company Lockout/Tagout procedure
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