Unfolding Lockout/Tagout (LOTO)!

An OSHA/legal definition of de minimis and a clearer understanding of – What do employees need to know? will certainly help all companies unfold LOTO for full compliance.

01/31/2011


DANGER - This energy source has been locked out - proper machine safety methods save life and limb, says the Control Engineering Machine Safety blog.Hazardous energy must be controlled when employees are servicing and maintaining machines in order to prevent serious physical harm or even death. To address this hazardous issue OSHA created The Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147. As a reference source, OSHA used ANSI Z244.1-1982 in the creation of this regulation and continues to reference Z244 on their web site. Since LOTO was created OSHA has issued several letters and Circulars of interpretations for application of the requirements and ANSI has also updated Z244.1 to the current 2003 issue. With all this said, why do you suppose levels of uncertainty seem to exist regarding “my requirements” vs the level of requirements simply laid out by OSHA, ANSI, and other consensus standards.

J.B. Titus, machine safety bloggerDo you think Richard E. Fairfax, Director, OSHA Directorate of Enforcement Programs, in his interpretation letter on this subject confused anyone when he brought the term “de minimis into the mix? Has anyone come across an OSHA regulation that describes the full legal interpretation of “de minimis”? How does industry properly and accountably apply this term to employee training and their company “Safety Policy” manual?

 

After further research I found an OSHA Fact Sheet. This two page summary on LOTO is a great summary. However, in my opinion it begins to get a little fuzzy in the section, What do employees need to know? See below:

“The training must cover at least three areas: aspects of the employer’s energy control program; elements of the energy control procedure relevant to the employee’s duties or assignment; and the various requirements of the OSHA standards related to lockout/tagout.”

Oh oh, this now begins to sound like a subject I’ve blogged on before titled, “Machine Safety and Your Safety Culture”. In my opinion, the last point in OSHA’s advice above unmistakably is about the LOTO regulation, 1910.147. Yet, the first two points sound more to me like parts of a company’s overall safety culture peppered with a little energy management to the chef’s taste. Does this begin to explain why there might be some traces of uncertainty regarding “my requirements”? What is measureable about these two points vs compliance to 1910.147?

An OSHA/legal definition of de minimis and a clearer understanding of – What do employees need to know? will certainly help all companies unfold LOTO for full compliance.  

INTEGRATED SAFETY COULD BE YOUR OPPORTUNITY – CONSIDER IT!

Submit your ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don't see a comments box, then scroll down: Unfolding Lockout/Tagout (LOTO).

Related articles:  

Machine Safety and Lockout/Tagout

Machine Safety And Your Safety Culture

Updating Minds About Machine Guarding

Contact: www.jbtitus.com for “Solutions for Machine Safety”.



No comments
The Top Plant program honors outstanding manufacturing facilities in North America. View the 2013 Top Plant.
The Product of the Year program recognizes products newly released in the manufacturing industries.
The Engineering Leaders Under 40 program identifies and gives recognition to young engineers who...
The true cost of lubrication: Three keys to consider when evaluating oils; Plant Engineering Lubrication Guide; 11 ways to protect bearing assets; Is lubrication part of your KPIs?
Contract maintenance: 5 ways to keep things humming while keeping an eye on costs; Pneumatic systems; Energy monitoring; The sixth 'S' is safety
Transport your data: Supply chain information critical to operational excellence; High-voltage faults; Portable cooling; Safety automation isn't automatic
Case Study Database

Case Study Database

Get more exposure for your case study by uploading it to the Plant Engineering case study database, where end-users can identify relevant solutions and explore what the experts are doing to effectively implement a variety of technology and productivity related projects.

These case studies provide examples of how knowledgeable solution providers have used technology, processes and people to create effective and successful implementations in real-world situations. Case studies can be completed by filling out a simple online form where you can outline the project title, abstract, and full story in 1500 words or less; upload photos, videos and a logo.

Click here to visit the Case Study Database and upload your case study.

Maintaining low data center PUE; Using eco mode in UPS systems; Commissioning electrical and power systems; Exploring dc power distribution alternatives
Synchronizing industrial Ethernet networks; Selecting protocol conversion gateways; Integrating HMIs with PLCs and PACs
Why manufacturers need to see energy in a different light: Current approaches to energy management yield quick savings, but leave plant managers searching for ways of improving on those early gains.

Annual Salary Survey

Participate in the 2013 Salary Survey

In a year when manufacturing continued to lead the economic rebound, it makes sense that plant manager bonuses rebounded. Plant Engineering’s annual Salary Survey shows both wages and bonuses rose in 2012 after a retreat the year before.

Average salary across all job titles for plant floor management rose 3.5% to $95,446, and bonus compensation jumped to $15,162, a 4.2% increase from the 2010 level and double the 2011 total, which showed a sharp drop in bonus.

2012 Salary Survey Analysis

2012 Salary Survey Results

Maintenance and reliability tips and best practices from the maintenance and reliability coaches at Allied Reliability Group.
The One Voice for Manufacturing blog reports on federal public policy issues impacting the manufacturing sector. One Voice is a joint effort by the National Tooling and Machining...
The Society for Maintenance and Reliability Professionals an organization devoted...
Join this ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis...
IMS Research, recently acquired by IHS Inc., is a leading independent supplier of market research and consultancy to the global electronics industry.
Maintenance is not optional in manufacturing. It’s a profit center, driving productivity and uptime while reducing overall repair costs.
The Lachance on CMMS blog is about current maintenance topics. Blogger Paul Lachance is president and chief technology officer for Smartware Group.