The Control of Hazardous Energy (lockout/tagout) Standard is the fourth most frequent source of OSHA citations. Only Scaffolding, Hazard Communication and Fall Protection standards get cited more. Why are there so many citations under lockout/tagout?
Some employers get tripped up on the inspection provisions of the standard. It's not enough just to have energy control procedures. You need to periodically inspect those procedures - and certify this to OSHA.
What the Standard Requires
The lockout/tagout standard requires you to establish energy control procedures to ensure that dangerous equipment remains shut off and doesn't unexpectedly energize, start up or release stored energy during servicing. This involves setting up a program and following procedures to affix lockout devices such as combination locks and tagout devices such as warning tags, to prevent injuries to workers servicing the equipment and others nearby. The standard also requires employers to inspect their energy control procedures at least once a year to ensure that workers are following them.
How to Conduct the Inspection
The first step is to designate an inspector. This should be somebody who services equipment at your facility; but the inspector can't inspect energy control procedures that he actually uses. So inspectors shouldn't inspect the equipment they service.
The inspector is supposed to review the energy control procedures to ensure they comply with OSHA standards and that all workers who are supposed to follow the procedures have copies of them. The inspector should also meet with the workers as part of the inspection.
If the inspection covers energy control procedures involving lockout, the inspector must meet with each worker who uses the procedure inspected and ask them to explain their responsibilities under the procedures. If workers aren't clear about certain aspects of the procedure, the inspector should explain the correct procedure and make a note indicating that additional training may be needed.
While inspecting tagout procedures, the inspector must do a review not just with each worker who uses the procedure but also workers who work in the immediate area or who use the particular equipment or machine. The inspector must meet with each worker and verify that the worker understands:
- His or her responsibilities under the procedures;
- The limited protection provided by tagout; and
- That he or she is not to remove a tagout device that's been placed on equipment or attempt to bypass or otherwise override it.
[Editor's Note: Next week, in Part 2 of this series, we'll explain how to properly certify and document your inspection. ]
MESDAMES & MESSIEURS:
How the Above Story Applies to Canadians
Most of Hal's story applies equally in Canada.
Explanation: Unlike in the U.S., there's no single lockout/tagout standard that applies equally across Canada. Having said that, each province, territory and the federal jurisdiction require locking out and controlling energy sources of machinery during servicing.
However, not all of the OHS laws specifically mention inspection of energy control procedures the way the U.S. OSHA standard does. Still, the duty to monitor the effectiveness of safety measures is at least implicitly required by Canadian OHS laws. And if you need to do the inspection, you need to document the inspection. So Hal's advice will work for you too.
When Hal starts talking about the specific procedures to use, keep in mind that these are mandated by the U.S. OSHA standard. If you're Canadian, you can do it differently. In fact, you might have to do it differently if your province sets out an exact procedure to follow.
Is Doing One's Business Doing Business under Workers' Comp?
What Happened: An Arkansas worker gets hit by a truck coming back from the restroom. The state Workers' Comp Board denies his claim. The worker's injury wasn't work-related, the Board says, because going to the bathroom isn't part of an employee's job function. The worker appeals to the state Supreme Court.
Answer: The worker. The Arkansas Supreme Court rules that a bathroom break "was a necessary function and directly or indirectly advanced the interests of his employer."
Editor-in-Chief's Note: Thanks to SafetyXChange Board member Richard Hawk for submitting this gem.