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EHS INSIDER

Archived Article
 

LOCKOUT/TAGOUT


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 training.

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.

Partial Exemption

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:

  1. The machine/equipment has no potential for stored or residual energy after shutdown that would endanger an employee.
  2. The machine or equipment has a single energy source that is identifiable and capable of isolation.
  3. The isolation and lockout of that energy source will completely de-energize and deactivate the machine or equipment.
  4. The machine or equipment is isolated from that energy source and locked out during service or maintenance.
  5. A single lockout device will achieve a locked out condition.
  6. The lockout device is under the exclusive control of the authorized employee performing the service or maintenance.
  7. The servicing or maintenance does not create hazards for other employees.
  8. 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 compliance.

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 the task.

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

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:

  1. 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.
  2. 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 is prohibited.
  3. 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

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 Yoder.

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