By Cari Gray, BWC Industrial Safety Consultant Specialist
The Occupational Safety and Health Administration (OSHA) has a standard called the Control of Hazardous Energy – most folks know it as lockout/tagout. This standard is one of the most important in all of OSHA’s regulations; still many do not understand or do not follow the rules. In 1990, this rule became law in a response to 122 fatalities and approximately 50,000 injuries per year. This OSHA law is 29 CFR 1901.147.
The theory behind the law is simple: if you have workers exposed to hazardous energy, you must stop the energy and lock out the energy source to prevent accidental releases that can cause injury.
OK, maybe that doesn’t sound simple – so let me give you an example. If you are changing a ballast in a light fixture, you must lock out the breaker or disconnect it while doing the work so others do not accidently turn it on. Or if you are repairing a large fan, you must put a lock on the energy source (like a breaker) so your co-worker cannot turn the fan on while your hands (and maybe your head) are in the machine.
That sounds pretty important, right? There is plenty of potential for fatalities while working on any type of equipment, this standard and these rules can keep you safe, maybe even alive, to work another day.
From a regulation standpoint, there are multiple parts to the standard. The scope of the standard defines what is included and not included. Example: the standard does not cover work on live electrical. You should never work on live electrical. However, if you do, you must follow OSHA Subpart S and the NFPA 70E standards. There are also definitions covering who the players are and their roles.
The main parts of the standard are the written program, energy control procedures, periodic inspections and training. There are very specific requirements about the equipment workers use for lockout/tagout as well as detailed instructions for group lockout, shift changes and outside personnel. I’ll focus on the four main sections I listed above.
First, a written program: This is a must and required by any company that has an energy source that could cause harm. Even if you do not perform the work internally, you must have a plan in place to ensure injuries do not occur. The written program – OSHA calls it the Energy Control Program – must be in writing and be an overview of your plan. This plan includes roles, responsibilities, procedures, inspections and training. This is the overview of how you plan to manage your program.
Energy control procedures
Energy control procedures, oh energy control procedures. This may be the most difficult and tedious of the requirements, but it is oh so important. Develop, document and use the procedures when an employee performs work that could cause the release of hazardous energy. There is a defined list of requirements you must include in the procedures, including, scope, purpose, authorization, rules, enforcement and techniques for actually performing lockouts.
Periodic inspections is code for ANNUAL inspections, and don’t forget to do them. The purpose of the annual inspection is to check the written program, the energy control procedures and the training effectiveness. So yes, you need to look at all the written documentation and watch authorized employees actually lock out some of the equipment.
You’ll need to provide some level of training to all employees. Affected employees (those that can be impacted by lockout, but don’t actually do it) must have basic training on what lockout is and what to do if they are affected by a piece of equipment other workers are locking out (aka leave it alone). Authorized employees get the most training because they are responsible for locking out the equipment so they can stay safe. There is no annual requirement for retraining. However, there are many circumstances where employees need retraining, like changes and failure to follow the rules.
The importance of locking out can’t be shouted loud enough. There are too many examples of workers not using lockout with horrific consequences. The 18-year-old caught in a large shredder. A 50-something accidentally pulled into a washer. The maintenance worker electrocuted while changing a live outlet at a nursing home. Unfortunately, I could go on for hours. Accidents can strike any industry, any age and any employee skill level. If a company’s management doesn’t take lockout/tagout seriously, neither will workers.
Don’t feel helpless if you don’t have a program or you’re worried yours isn’t up to par. Our Division of Safety & Hygiene offers classes, videos and expert safety consultants to help you develop or evaluate your program. Just contact them!