Many people in general industry are all too familiar with some of the vague or confusing requirements in OSHA’s lockout/tagout regulation 1910.147. In my years working with Conversion Technology, and visiting all sorts of different manufacturing sectors, there have been several mistakes and misconceptions regarding lockout/tagout that have popped up.
- Lack of Procedures
Specific procedures need to be written for all equipment where the unexpected energization, start up, or release of energy could cause injury. These specific procedures should identify all energy sources and the required energy isolation devices.
- Training of Employees
Most facilities I visit do typically do a fantastic job making sure that those employees who apply locks and tags, and those who perform maintenance (also known as “authorized employees”) are properly trained on the safe application of a lockout/tagout programs and understand how to follow specified lockout/tagout procedures. OSHA’s lockout/tagout regulation also requires training be conducted for “all other employees”, which usually include both management and staff who occasionally walk near equipment that is locked or tagged out.
- Working Under Someone Else’s Lock
Each employee working on a piece of machinery should apply his/her own lock. No employee should take the responsibility of another person’s life when lockout/tagout is involved. Also, under no circumstance should an employee use the lock belonging to another individual.
- Not Bringing Equipment to a Zero Energy State
It is very important to bring equipment to a Zero Energy State prior to conducting maintenance on it. In my experience, OSHA can look at your lockout procedures specifically for the steps that bring the equipment to a zero energy state. Aside from this being covered in the regulation, and being a big hit spot for OSHA inspectors, equipment in a zero energy state are severely less likely to pose a hazard of injury or death on employee conducting maintenance on the equipment.
- I Don’t Need to lockout, This Job Will Only Take a Few Minutes
This should never happen. When an employee rushes to finish working on a machine because they don’t feel like conducting the full lockout, accidents happen.
- I Don’t Want to Lose My Key
Often an employee does not want to deal with the hassle of possibly losing their key, so they leave it in the lock. So many things can go wrong here. Now any person can walk up and remove the lock, not knowing that someone is inside the equipment performing maintenance.
- Wrong Use of Locks
Simple. A lockout lock’s only purpose is for locking out equipment. Under no circumstance is a lockout lock to be used to lock a toolbox or personal locker.
- Annual Audit of Procedures
OSHA requires a review of all lockout/tagout procedures for all authorized employees. These employees are to physically follow the procedures and conduct lockouts in order to ensure all energy sources have been identified and that employees understand the procedures and energy isolation techniques.
29 CFR 1910.147: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9804