Tackling OSHA’s Top 10 Citations: 1910.147 - Lockout/Tagout
The following is an excerpt from Tackle OSHA’s Top 10.
Hosted by Chief Safety Officer Jill James, you can listen to the webcast on demand.
The fifth most cited hazard is lockout/tagout.
I guess a fallacy that people often think about with that is we lock out energy sources when something is broken. And that's true, and it certainly can happen at that time, but it's also about when employees are going to do maintenance, repair work, dig into the inner workings of something where there could be stored energy that could harm them.
So stored energy could be what we're seeing in the top photo. Maybe it's a valve that has a gas, or a liquid, or a water source, or perhaps it's a valve like you're seeing at the bottom picture. There are a lot of different devices that are manufactured to make it impossible for people to turn something on, and put someone else in jeopardy. There's a lot of different things on the market, and methods to use, to physically turn off and lock out the energy source.
Everyone's probably most familiar with this one on the left, where we're locking out the typically breaker panel, but there's lots of different energy sources. It could be electrical. It could be gas, pneumatics, water, and even gravity. So what we're seeing on the right is a device that's used to lock out gravity sources.
So you think about something that's held aloft, that could fall or crush onto someone. Often, you'll see that with like rams, maybe in a punch press situation, or the first thing that I think of is a fatality investigation that I did once, where a man was under a truck. It was a concrete mixing truck, and concrete mixing trucks have what's called a pusher axle. It's an extra axle that's held aloft until they need it, if truck is full, and they're going to drop this axle onto the road.
The employee was in the maintenance shop, working on a crawler, a creeper, under the concrete truck itself, and the pusher axle was in its up position, not touching the ground, and the employee was under it, and doing some work, and he inadvertently disconnected something, and that pusher axle crushed the employee's chest and suffocated him under the truck. So how would've we prevented that kind of energy source from being discharged? Well, we would have put some blocks under that pusher axle, so it couldn't have fallen on top of the employee. So keep that in mind when you're doing your evaluations on energy sources, to be mindful of all the different types of energy sources that there are, and it's not simply limited to electricity.
Some other things that you should know, that you'd be asked about, is any time you have more than one energy source associated with a piece of equipment. Maybe it's something that's hydraulic and electric. Any time you have more than one energy source, then you have to have written, step-by-step procedures that explains how to de-energize that piece of equipment, where to apply the locks, how to ensure and test that the energy has been displaced, then what are the rules for re-energizing as well.
So those have to be in writing, and they have to be for each piece of equipment that you have, that has more than one energy source. For pieces of equipment that are just cord and plug connected, and the person working on that piece of equipment can have visual sight of that cord and plug, then you don't have to have step-by-step procedures for that.
Then, once you get those step-by-step procedures written, and it is an awful lot of work, then you have to review those procedures annually. That's required and written into the law as well, to see if anything's changed in the past year, with that particular piece of equipment. Then be mindful of knowing the lockout devices in the market changes, and that there's so many different types of technologies out there.
Be sure to be checking with vendors, about what's new that we could be using now, and that you're locking out all possible energy sources, and any time you have more than one person working on a particular piece of equipment, or in a situation, every single human being that has exposure to that area has to have their own physical lock applied, so that the last person out would be the last person to take their lock off, and then to do the re-energization, so that we're making sure that we're not exposing or leaving someone in a particular area where we didn't know someone was in a tank, and somebody else thought the work was done, and they fired it up, and they got twisted up in a mixer or something. Those are standard things that can happen, and have happened.
So is logout/tagout training required? Yes it is.