You’re allowed to add more information to a machine LOTO procedure than OSHA requires, but make sure it’s clear so it doesn’t inadvertently endanger workers.
By Leah Shenold, lockout/tagout engineer, Rockwell Automation
Lockout/tagout (LOTO) procedures are designed with the safety of maintenance professionals in mind, but they also consider workers who are around or operate machines. For instance, OSHA cited an automation company for nine violations in connection with a worker’s fatal injuries when the worker was caught and pinned by a conveyor that had lowered during a power-down process. He died about a week later. Two of the nine violations related to their failure to implement an effective LOTO program for machines’ energy sources and to train workers on proper procedures.
And that’s just one example of thousands of LOTO-related accidents that happen every year, sadly. Because multiple audiences need to read procedures, it’s important to be intentional about the information provided within each LOTO procedure and how it’s presented.
According to Occupational Safety and Health Administration (OSHA) regulation 1910.147, LOTO procedures “shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance.” This means that each procedure should be clear and concise about the following things:
- Which piece of equipment the procedure pertains to.
- Who is qualified and allowed to perform the LOTO.
- The steps to be taken to perform LOTO properly.
- What the consequences will be if someone does not follow the LOTO procedure.
These steps should include information about the type of energy, methods for controlling the energy and methods for verifying the lockout.
Additions: Helpful or Unnecessary?
What else could be added to procedures to make them more helpful? Often, there may be an opportunity to add more information to the procedure than is required by OSHA 1910.147.
Sometimes these additions are helpful, making a machine’s de-energization easier. But additions also can clutter the document, hindering clear understanding of the procedure. It is important to keep in mind who is going to be using the procedures when deciding what information is necessary.
Examples of helpful additions include:
- Steps that instruct the authorized user to confirm that a certain valve be opened or closed to release pressure from a system.
- Notes about associated equipment that must be shut off for employee or system safety.
- Warnings about backup units that must be kept on, such as a backup pump, to make sure normal plant operations aren’t interrupted.
- Other important warnings to verify that nothing goes awry when LOTO is being performed.
These additions can come into play in many industries. For example, it could be a plastic forming facility with a whole line of interconnected equipment. If someone wanted to work on an extruder, then there might be a note on the procedure document to shut down the former that it is feeding as well as the blending unit that is supplying the extruder with plastic pellets.
Another example is a dairy facility, where work might need to be done on a Clean-in-Place (CIP) pump. If this was the case, then there may be instructions to reroute the CIP system to another CIP pump so that the process isn’t interrupted and everything can continue on smoothly.
Examples of unnecessary additions are:
- Information not relevant for de-energizing a machine.
- Information on how to service the equipment, which is better documented separately in a preventive maintenance work instruction.
- Instructions or explanations that have been elaborated on, which can obscure critical information.
- Instructions that contain all the information that ever may be desired on a LOTO procedure “just in case,” instead of using employee trainings or other methods to share that knowledge.
Many companies try to add extra information to their LOTO procedures, because they see it as being helpful and necessary. However, this isn’t always the case.
For example, there have been instances when companies have attempted to include an Alternative De-energization Procedure (ADP) in their LOTO procedures. Someone looking at this and attempting to follow the section detailing how to lock out a piece of equipment might get confused and follow the ADP instead. If this were to happen, that person possibly could be put in harm’s way because the equipment is not fully locked out.
Procedure Documentation Types Should Vary
There isn’t one exact set standard for procedures, because they can vary depending on company and industry. OSHA allows freedom in the implementation of the procedure format as long as the regulation’s intent and minimum requirements are met. You might need to add small details that can make a LOTO procedure more specific and helpful. Many documentation formats can be used for a LOTO procedure.
The way a procedure is documented can make a big difference to the person trying to carry it out correctly. The types of procedure documentation will vary depending upon each company’s size and needs.
When authorized employees are locking out equipment, especially complex pieces, it’s generally recommended to use a graphical format. Graphical procedures tend to provide the clearest, most easily accessible and visually appealing guidance for employees so it doesn’t confuse or distract them from performing the lockout safely.
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