NOT JUST FOR MANUFACTURING WORKPLACES
It is easy to associate the need to lockout equipment and machinery
during servicing or maintenance with manufacturing environments
where large industrial machines and equipment are in use. However,
lockout is not just a requirement for manufacturing, it applies
to all general industry workplaces where employees are required
to service or perform maintenance on equipment.
During the past three years, MIOSHA has cited lockout in more
than 275 nonmanufacturing workplaces, with 370 individual violations
cited and more than $165,000 in initial assessed penalties. These
workplaces include restaurants, grocery stores, warehouses, repair
shops, nursing homes, municipalities, scrap yards, lumberyards,
department stores, dairies, and bakeries, among others. A recent
workplace fatality also underscores the important role of locking
out. This fatality occurred at Jeepers in Livonia. Jeepers is
an indoor amusement facility that provides a variety of attractions,
such as mechanical rides, games, refreshment stands, and dining
areas. The amusement manager was struck by the lead car of a five-car
roller coaster while performing a maintenance inspection of the
roller coaster track. The ride operator did not realize the amusement
manager had entered into the area and did not immediately realize
the car had struck the employee.
Passengers in the roller coaster indicated they had made three
circuits of the track when the employee knelt down in the track
and appeared to be examining something near the track. A screwdriver
was seen on the floor near the incident and a setscrew identical
to those found on the ride was near the employee. The firm received
a citation for failing to ensure that employees engaged in maintenance
operations utilize lockout to prevent start-up of the roller coaster,
and for not training employees.
In recent years, the following workplace deaths where lockout
was a factor have occurred at nonmanufacturing sites:
- The owner of a family-owned and operated bowling center
was fixing a pin-setting machine. Power to the machine was not
shut off even though the owner had previously trained family members
on lockout and had placed warning signs on the back and top of
the machines warning them to shut off power before entering the
machines. The owner was crushed by the machine and died of asphyxiation.
The company was cited for failing to utilize lockout procedures.
- A sales person/route driver of a dairy supply company
was sent to repair a bulk cooler/washer at a farm. while making
the repairs, the individual contacted live electrical wires and
was electrocuted. The company was cited for failing to provide
electrical lockout procedures and training.
- A maintenance mechanic at a commercial laundry climbed
inside a commercial tumbler to dislodge an article stuck in the
top section of the door. White the worker was inside the door
closed and the tumbling cycle started. When the tumbler finished
the cycle, it emptied its load onto a conveyor belt. The employee
was found approximately 25 minutes later, coming down the conveyor.
The company was cited for failing to provide the equipment with
energy-isolating devices, for failing to develop and implement
lockout procedures, and for failing to provide training to authorized
and affected employees.
These tragic examples illustrate the critical need for lockout
while performing service and maintenance work. No matter what
type of workplace, if there is equipment and machinery in use
with moving parts, people can be hurt. Employers must take the
steps necessary to ensure that employees know when to use lockout
and how to do use. They also must provide adequate equipment and
Energy Control Programs
MIOSHA Part 85, Control of Hazardous Energy Sources, requires
employers to plan for the control of energy during servicing and/or
maintenance of machines where unexpected energization or motion,
start up, or release of stored energy could cause injury. It requires
that employers plan for the control of energy by doing the following:
- Establish an energy control program;
- Develop, document ,and utilize lockout/tagout procedures;
- Provide employees appropriate training;
- Provide, at no cost to the employees, equipment required by the lockout/tagout procedures;
- Ensure continued competency through inspections and retraining.
Part 85 covers servicing and maintenance of machines, equipment,
and associated activities. The purpose is to protect employees
from injury due to unexpected or unintended motion, energization,
start-up, or release of stored energy from the machine, equipment,
or process. Energy sources include electrical, pneumatic, hydraulic,
mechanical, thermal, and chemical. There may also be stored or
residual energy that may remain once the primary energy source
is shut down. Stored energy may result from steam, air pressure,
compression of springs, electrical capacitors, or gravity.
Normal production-type operations are not covered by the standard.
However, servicing and/or maintenance during normal operations
are covered in the following circumstances:
- An employee is required to remove or bypass a guard or other safety device;
- An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed;
- An employee is exposed to an associated danger zone during a machine operating cycle.
In addition MIOSHA Part 40, Electrical Safety-Related Work
Practices, addresses safe work practices including lockout where
the hazard to the employee is electrical.
Other MIOSHA standards may apply to specific processes or industries
that may also contain lockout requirements that go beyond Part
85 and Part 40. In these cases, the lockout requirement of the
specific standard preempts the tagout option contained in Part
85. The procedural and training requirements of Part 85 continue
to apply so that the end result is a complete program for protecting
employees from energy hazards.
Employers must put in place procedures for lockout if employees
are engaged in activities covered by the standard. Generally,
lockout procedures must be documented-in writing. However, the
standard provides a partial exemption from the requirement to
have procedures in writing when eight specific criteria are met.
Equipment must still be locked out following established procedures.
The eight criteria are:
- The machine/equipment has no potential for stored or residual energy after shutdown that would endanger an employee.
- The machine or equipment has a single energy source that is identifiable and capable of isolation.
- The isolation and lockout of that energy source will completely de-energize and deactivate the machine or equipment.
- The machine or equipment is isolated from that energy source and locked out during service or maintenance.
- A single lockout device will achieve a locked out condition.
- The lockout device is under the exclusive control of the authorized employee performing the service or maintenance.
- The servicing or maintenance does not create hazards for other employees.
- The employer utilizing the exception has had no accidents involving the unexpected activation or energization of the machine or equipment during service or maintenance.
Cord and Plug-Connected Equipment
In nonmanufacturing settings, cord and plug-connected equipment
is frequently used. Examples include grinders and saws in meat
markets and grocery stores, mixers in bakeries, washing machines
at nursing homes, or vacuum cleaners used in offices.
The lockout standard allows unplugging as an alternate means
of protecting employees performing covered tasks if the employer
has taken some key steps. These steps are evaluating the equipment,
training the employees, and supervising the employees to ensure
For cord and plug-connected equipment to qualify for this exemption,
the employer must evaluate each piece of equipment to ensure that
unplugging, following a normal shut down, controls all hazards
of unexpected energization or start-up of equipment. The cord
and plug must be arranged so that it is possible for the employee
doing the task to maintain exclusive control of the unplugged
cord. This means that the employee needs to be able to follow
the cord from the equipment to the plug and after unplugging,
keep the plug in plain sight and within arms reach while performing
Employee training must stress:
- Exactly which equipment is covered by this exemption;
- The need to test the equipment after unplugging;
- The need to continuously monitor the plug while performing the task;
- Which tasks are allowed under this exemption.
For example, a meat cutter might be allowed to use this technique
while cleaning a large meat cutting band saw, but maintenance
personnel rebuilding the same saw might require other procedures
to be followed to protect them from the hazard of compressed springs.
Since this exemption is one hundred percent dependent upon
employee compliance, adequate supervision is essential. Many routine
cleaning tasks are conducted this way, and any cleaning task in
the vicinity of the operating control has the risk of inadvertent
operation of the control. Thus each and every failure to follow
the procedure might lead to an employee injury.
Training for employees must cover, at a minimum, the following
three areas: the energy control program, elements of energy control
procedures relevant to employee duties, and applicable requirements
of the lockout standard. The standard provides for three levels
of training which depend on the duties assigned to the employee.
The three levels are:
- Authorized employees are those who have received proper
training and will be authorized to perform lockout in the facility.
These employees must be trained to recognize the location, type,
and magnitude of potential hazardous energy sources in the workplace;
the proper lockout/tagout procedures to use; the proper lockout/tagout
devices (and any related equipment) to use; how to properly remove lockout devices;
and an explanation of the applicable MIOSHA standards.
- Affected employees are those who work in areas where equipment
will be locked out. These employees need to understand the purpose
and use of lockout. Training for affected employees must include:
the purpose of the lockout procedures, when and why lockout procedures
are used, and an understanding that tampering with lockout equipment
- Other employees are any other people whose work operations
are, or may be, in an area where energy control procedures may
be utilized. For these employees, training must include instruction
on the employer's lockout procedures. The employees must be aware
that they cannot attempt to restart or re-energize machines or
equipment that are locked out or tagged out of service.
Periodic inspections of lockout procedures must occur annually.
Periodic inspections must, at a minimum, provide for a demonstration
of the procedures and my be implemented through random audits
and planned visual observations. These inspections are intended
to ensure that the energy control procedures are being properly
implemented and to provide an essential check on the continued
utilization of procedures.
Whether you are a grocery, bakery, warehouse facility, hospital,
public works department or any of the other hundreds of kinds
of businesses in Michigan-if you require employees to perform
servicing or maintenance, remove or bypass guards to perform tasks,
place any part of their body in the point of operation of equipment
or a machine, or be exposed to associated danger-you must take
steps to safeguard your employees through effective implementation
and use of lockout procedures.
From the spring 2003 issue of MIOSHA News, written by Martha