The Control of Hazardous Energy Enforcement Policy

1
The Control of Hazardous Energy Enforcement
Policy Inspection Procedures
Advanced Technologies and
Laboratories International, Inc.

• OSHA INSTRUCTION CPL 02-00-147
• Walt Siegfried CSP, MSSenior Program Manager

2
Topics

• Why did OSHA create a revised directive?
• How can CPL 02-00-147 help you?
• What are some policy issues that can be answered
  in this instruction?
• How can you use this Manual?

3
Why?

• To evaluate the effectiveness of an OSHA standard
• Pursuant to Regulatory Flexibility Act
  Executive Order 12866
• Look-back recommendation
• Standard should remain in effect is necessary
  to protect employees reduction in LOTO
  fatalities
• There is still a substantial amount of
  non-compliance
• 3rd most cited 1910 standard in 2007
• 392 Federal fatality inspections w/ LOTO
  violations 10/02 9/07
• Expanded to include all energy control standards

4
Why a Manual?

• Provide OSHA staff guidance on
• Interpretations of standards
• Alternatives to LOTO
• Uniform inspection procedures
• Citation policy
• Consolidate energy control policy
• Provides others with valuable insight

5
How Can the Manual Help You?

• Understand how to integrate apply hazardous
  energy control standards
• LOTO (1910.147) (including the minor servicing
  exception)
• Machine Guarding (1910, Subpart O)
• Electrical (1910.332 1910.333)
• Vertical LOTO provisions (such as permit-required
  confined space)

6
Hydraulic Press Example

• Depending on the servicing maintenance task
  performed, hazardous energy control steps may
  involve
• Lockout (safety blocks, disconnect switch,
  hydraulic valve)
• Safeguarding (2-hand control)
• Electrical safe work practices (by a qualified
  electrical person)

7
Die-set Example

• Die-set procedure utilizes LOTO safeguarding
• LOTO works in conjunction with machine
  safeguarding
• Safety blocks are energy isolating devices
• Two-hand safeguarding devices do not control all
  types of hazardous energy, but do protect
  die-setter during inch/jog operations
• See 22 APR 2005 letter to Lockton Companies

8
Supplemental Aspect

• 1910.147 procedure training provisions
  supplement other vertical LOTO standards to the
  extent that they are not regulated by the
  specific LOTO provision
• Some other standards that have LOTO requirements
• Telecommunications (1910.268)
• Permit-required confined spaces (1910.146)
• Overhead cranes (1910.179)
• Mechanical power presses (1910.217)
• Grain handling (1910.272)

9
How Can the Manual Help You?

• Understand the OSHA standards on controlling
  hazardous energy (lockout/tagout or LOTO)
• Assist in program development
• Energy control procedures
• Training communication
• Periodic inspections
• Detailed explanations on key topics
• Scope application
• Procedures
• Group LOTO
• Periodic inspections

10
Key Definitions

• Hazardous Energy
• Energy that could cause injury to employees
• Servicing and/or Maintenance Activities
• Constructing
• Installing
• Setting up
• Adjusting
• Modifying
• Maintaining
• Cleaning
• Un-jamming

11
Key Definitions, contd

• Authorized Employee
• Performs equipment service/maintenance
• Performs energy isolation
• Implements LOTO on equipment
• Dissipates stored energy
• Verifies isolation
• Implements actions to release LOTO
• Tests or positions equipment components

12
Key Definitions, contd

• Energy Isolating Device
• Physically prevents the transmission of energy
• The Note links JAN 2008 letter on programmable
  logic controllers e.g., program errors,
  magnetic field interference, surges, component
  failure, improper use
• Exclusive Control
• Employee has the authority to and is continuously
  in a position to prevent individuals from
  reenergizing equipment

13
Policy Issues

• Scope application
• Energy control programs
• Tagout programs
• Specific procedures
• Training
• Periodic inspections
• Group LOTO
• Vehicles
• Alternatives, including minor servicing exception

14
Scope and Application

• Normal production operations
• Utilization of equipment to perform its intended
  production function
• Usually covered by Subpart O
• LOTO standard
• Covers the control of energy during machine
  servicing/maintenance where injury may result
• Both potential kinetic energy

15
Purpose Statement 1910.147(a)(3)

• Employers must establish an energy control
  program
• Employers must utilize procedures for affixing
  LOTO devices to energy isolating devices
• Employers must otherwise disable/shut down
  machines/equipment to prevent unexpected
  energization, start-up or release of stored
  energy to prevent employee injury

16
Energy Control Program
Energy Control Procedure
Employee Training
Periodic Inspection


17
Tagout Programs
Lockout Program Level of Safety
Tagout Program Level of Safety

18
Tagout Interpretation (14 Oct 1999)

• Comprehensive tagout program
• Additional training inspection provisions
• Full employee protection - Tags Plus ()
• Verbal accountability ? personal LOTO devices
• Administrative control accountability devices
• Lockout is preferred!

19
LOTO Device Equivalency
Equipment Lockout Device
Equipment Tagout Device
Full Employee Protection Tags Plus


Capable of being locked out Grandfather
Dates 1910.147 - 2 JAN 1990 1910.269 - 1 NOV
1994
20
Tag Plus () Examples

• Fuse removal
• Retracting a draw-out circuit breaker
• Blocking mechanism on switch
• Opening additional switches
• On main circuit
• On control circuit
• Grounding the circuit
• Double block bleed

21
Energy Control Procedures

• Control procedures must provide
• Sufficient detail
• Specific guidance for the energy control steps so
  that authorized employees clearly understand how
  to safely utilize control measures for the
  machine being serviced or maintained

22
Specific Procedures

• OSHA retained the word specific in the final rule
  because overgeneralization does not provide
  employees with sufficient information to
  effectively control hazardous energy
• Generic procedures alone are unacceptable
• Work permits, checklists, placards may be used to
  supplement generic procedures

23
Hazard Analysis

• Foundation of sound energy control procedures
• OSHA does not approve or certify hazard or risk
  analyses
• OSHA staff may apply recognized analyses to
  document hazards
• System safety expertise may be required for more
  complex analyses

24
Training

• Employees are critical to the success of the
  program
• Must be properly trained
• Must be proficient in their energy control
  responsibilities
• Training needs to be commensurate with specific
  job responsibilities
• Authorized employees
• Affected employees
• Other employees

25
Training, contd

• Areas to cover, depending on job function
• Purpose scope of program
• Elements of procedures relevant to employee
  duties
• Pertinent LOTO standard requirements
  prohibitions
• Training certification
• Both initial retraining
• Demonstrates that training was provided
  understood
• Employee proficiency skills diminish with time

26
Periodic Inspections

• Annual inspection of each procedure
• Review employee responsibilities observe
  interview
• Authorized employees for LO
• Authorized affected employees for TO
• Purpose is to verify
• Procedure steps are followed
• Employees know their responsibilities
• Procedure is adequate

27
Procedure Grouping

• Similar machines/equipment may be grouped if they
  are listed in the procedure scope all have the
  same or similar control steps to
• Shut down, isolate, block, secure dissipate
  stored energy
• Place, remove transfer LOTO devices
  responsibility for them
• Test a machine/equipment to determine verify
  effectiveness of control measures

28
Streamlined Process

• If the inspection sampling reasonably reflects
  hazardous energy control practices
• Inspect a representative of employees
  implementing the procedure
• Perform supplemental review with remainder of
  employees
• Used for same or similar machines or equipment
  that have same or similar control measures
• May be performed by group meetings

29
Other Program Elements

• Application of control release from LOTO
  sequential elements
• Hardware specifications
• Affected employee notification
• Shift personnel change
• Outside personnel

30
Group LOTO
Group LOTO
Equipment LOTO
Group LOTO Mechanism
Personal LOTO Devices



31
Type A
Personal LOTO Devices
Group LOTO Mechanism
Equipment LOTO
LOTO HASP
Electric Disconnect Switch
32
Type B
Personal LOTO Devices
Group LOTO Mechanism
Equipment LOTO
Master Lockbox/Tagbox
Diagram Legend
33
Types C D
Personal LOTO Devices
Group LOTO Mechanism
Equipment LOTO
Crew Leader
34
Vehicle Hazardous Energy Control

• Vehicle servicing and maintenance activities have
  caused serious injury death
• 1910.147 applies to general industry workplaces
  that service or maintain vehicles, such as
• Automobiles
• Trucks
• Tractors
• Transport vehicles
• Material handling equipment

35
Vehicle Hazards

• Shock (batteries, recharging equipment)
• Chemical (acid, coolants, lubricants)
• Mechanical (by components of or being run over by
  vehicles)
• Gravity (elevated vehicle components)
• Thermal (hot or cryogenic fluids)
• Hydraulic (loss of fluid pressure)
• Explosion (air bags)
• Fire (fuel)

36
Program Flexibility

• An energy control program is necessary
• Due to nature unique aspect of vehicle
  maintenance, the energy control measures must be
  tailored to the workplace
• For example, sole control of ignition key may
  provide protection in some, but not all,
  situations.

37
Vehicle Energy Control

• Manufacturers Recommendations
• Includes step-by-step instruction, to assist
  employers in comply with 1910.147
• Troubleshooting
• Diagnostic testing
• Maintenance troubleshooting
• Component positioning
• Supplemental safeguards and personal protective
  equipment

38
LOTO Alternatives

• Machine guarding
• Cord plug-connected equipment
• Control circuitry (variances)
• Other abatement methods

39
Safeguarding Equipment Preventing Amputations

• Primary Safeguarding
• Guards
• Safeguarding devices (e.g., light curtains,
  2-hand controls)
• Secondary Safeguarding
• Awareness devices
• Safe work methods
• Safe work procedures
• Complementary Equipment
• Augments, but is not, safeguarding (e.g.,
  e-stops, foot controls, hand-tools)
• See OSHA Publication 3170-02R 2007

40
National Consensus Standards

• Provide useful guidance to control energy hazards
• ANSI B11.19 2003 feasible machine tool
  safeguarding guidance
• ANSI O1.1 1992 woodworking machine safety
  requirements
• Are not automatically equivalent to OSHA standards

41
Other Control Methods

• Walking/working surfaces to provide safe access
• Personal restraints to avoid danger zone
• Safety control circuitry
• Control circuitry is not an energy isolating
  device
• Variance procedures (29 CFR 1905)
• Control circuits may be effective protection per
  the minor servicing exception

42
Minor Servicing Exception

• Limited exception!
• Work is minor in nature
• Routine repetitive
• Performed during normal production operations
• Integral to the use of the equipment for
  production
• Work is performed using alternative methods which
  provide effective protection

43
Legal Decisions

• Westvaco Corporation
• Work performed before the normal production
  operation (NPO) is not covered by the MSE
• Setting up prepares a machine to perform its NPO
  and, by definition, does not occur during NPO
• Falcon Steel Co.
• Party claiming benefit of exception has burden of
  proving scenario falls within exception
• Document specific inadequacies (i.e., injuries)
  with 1 or more MSE elements (e.g., to refute an
  employers claim that 1910.147 does not apply
  because of the exception)

44
Lockton Companies 24 Oct 2005 Letter

• Milling machine/drill press safeguarding tool
  change tasks
• ANSI B11.8-2001 provides guidance for milling
  machines safeguarding
• Cord plug-connected exception
• Minor service exception example with respect to
  effective protection
• Switches are in Off position
• Switches are properly designed applied
• Switches are under exclusive control of operator

45
Summary

• Establish an energy control program
• Use the policy for education training purposes
• Link to case law, interpretation letters, CSB
  NIOSH incident reports
• Understand that energy control standards are
  interrelated and how to apply them
• See Safety and Health Topics, Control of
  Hazardous Energy website
• http//www.osha.gov/SLTC/controlhazardousenergy/in
  dex.html