Updates



September 20, 2018
Getting Lockout / Tagout Compliance Perfectly A top OSHA enforcement target, LOTO is a rule too often misunderstood by employers.

The Occupational Safety and Health Administration (OSHA) Lockout/Tagout (LOTO) rules for industrial equipment are among the least understood and most-often violated by employers. And probably no rule is as costly if you get it wrong.

One of the most common misunderstandings arises over the fact that the LOTO standard does not cover normal production operations. Instead, the requirements apply to servicing and maintenance, or any production activity that requires an employee to remove or bypass a guard or other safety device.

It also applies if an employee is required to place any part of his or her body into an area on a machine or piece of equipment that is used to perform processing of materials. Otherwise, a different OSHA machine guarding standard requires employers to install and maintain appropriate guards for protecting employees who only operate the machines.

The LOTO and machine guarding standards tend to complement each other. One protects employees during normal production operations (guarding), while LOTO protects employees during servicing. Technically, OSHA cannot cite the same conduct as a concurrent violation of both standards.

The workers who service machinery risk serious injuries and even death, if what is termed “hazardous energy” is not properly controlled. The most common of these injuries are amputations or lacerations to body parts, in addition to electrocutions, burns and crushing/struck-by incidents.

OSHA says that craft workers, electricians, machine operators and laborers are among the three million workers who service equipment routinely and face the greatest risk. Workers injured from exposure to hazardous energy lose an average of 24 workdays for recuperation.

Failure to control hazardous energy accounts for 10% of the serious accidents in most industries.

“In other words, amputation injuries - often because of failure to implement LOTO - occur frequently, and when they do occur, employers must proactively notify OSHA about them, and OSHA is very likely to respond to the report by conducting an enforcement inspection,”

Since updated reporting requirements covering amputations became effective in 2015, more than 2,500 amputation injuries have been reported to federal OSHA each year. Reporting data also shows that in 2015, 2016 and 2017 OSHA responded to these reports by initiating an on-site inspection 59%, 49% and 47% of the time, respectively.

Each year OSHA publishes its list of the Top 10 most frequently cited standards. Although the ranking changes slightly from year to year, LOTO violations are always among the top citations. Last year - just like previous years - LOTO violations ranked in the Top 3 in general industry, and Top 5 overall. “Year in and year out, employers make the same mistakes and compliance officers scrutinize LOTO programs to the tune of thousands of individual LOTO violations, with 2,877 such violations issued in 2017 alone,”

In addition, the list has become a bit self-fulfilling, he observes. Because these standards are frequently cited, OSHA compliance officers specifically seek out the same violations of the LOTO standards during their inspections.

One of the main reasons LOTO violations remain high on OSHA’s frequently cited list is that for 12 years the agency has been implementing an enforcement National Emphasis Program (NEP) on amputations with a stated purpose of reducing machine and equipment hazards that cause amputations.

Last year, federal OSHA conducted more than 3,500 inspections under the Amputations NEP, constituting more than 10% of all federal OSHA inspections. It found about 7,800 violations and assessed more than $55 million in civil penalties. Employers in industries subject to the Amputations NEP should proactively audit their LOTO programs to find and fix deficiencies in both their written programs and in any gaps that exist between the written programs and what is being implemented.

The cost of violations can be high, including qualifying as a target for OSHA’s dreaded Severe Violator Enforcement Program (SVEP). One way to join this circle of shame is to have committed two or more willful or repeat violations related to a “high-emphasis hazard,” which includes amputations. This one enforcement category is responsible for pulling in nearly 70% of all SVEP-designated employers.

If your firm enters this elite group, it can be the subject of inflammatory public press releases branding the employer as a “severe violator,” your company’s name added to a public log of Severe Violators, face mandatory follow-up inspections at the cited facility, and up to 10 inspections at sister facilities within the same corporate enterprise.

Consequences also include enhanced settlement terms, such as corporate-wide abatement, and requiring third-party audits. In addition, LOTO violations are among the most frequently used for OSHA criminal prosecutions. The criminal penalty for willful violations causing loss of human life is set at $250,000 for individuals and $500,000 for organizations.

Although relatively rare, criminal charges stemming from serious injury and death due to LOTO accidents top the list of those brought (sharing that spot with deaths resulting from improper trenching in construction). “The risk of criminal charges, including potentially charges against individual managers, is another fine reason that employers should focus resources on LOTO compliance,”


What to Do, and What Not

Keep in mind that LOTO requirements apply only to servicing and maintenance, and production activities requiring removal or bypass of a guard or other safety device. This includes general industry workers who perform maintenance on the equipment, and who can be exposed to the unexpected startup (i.e., “re-energization”) of those machines.

Servicing and maintenance activities typically include tasks such as lubrication, cleaning, un jamming, making adjustments or tool changes. Typically, these activities are distinct from an employee’s normal - routine production. “Of course, if an individual is employed as a maintenance worker or repair-person, then performing servicing and maintenance is part of that employee’s normal activities.”

A common mistake employers make in applying the LOTO standard is to focus too narrowly on one type of hazardous energy, he adds. “Specifically, we have found that employers do a very good job of addressing hazardous electrical energy in their LOTO programs, but LOTO applies to every type of hazardous energy, including mechanical, thermal, hydraulic, pneumatic and gravity.”

That means employers must ensure employees who are performing servicing or maintenance on an industrial oven are protected from heat energy, that employees repairing a power press are protected from the gravity forces of a press in the upright position, and employees fixing a piece of air-powered equipment are safeguarded from an unanticipated release of air.

Inspections must be performed at least annually to ensure energy control procedures continue to be implemented properly, and affected employees are familiar with their responsibilities. Another issue arises because many employers neglect to carry out LOTO inspections each year. However, employers more often fail to conduct them in the manner expected by the standard.

Once the periodic inspections are completed, the employer must ensure any deficiencies or deviations are corrected and certify, in writing, the inspection was performed. This certification must include the machine or equipment that was inspected, date of the inspection, employees included in the inspection and the name of the inspector.


“Unexpected Energization”

Confusion also surrounds the application of LOTO regarding “unexpected energization,”.

The OSHA standard does not apply if workers are not exposed to unexpected energization. That means that even while an employee is performing maintenance in the guts of a machine, LOTO is not required if employees would otherwise become aware the machine was about to energize.

For example, if the machine automatically sounds an alarm or flashes strobe lights for several seconds before a piece of equipment begins to operate, and there is no mechanical way for those warnings to be defeated, then it cannot be said that the energization was unexpected.

Editor points out that while many employers do a very good job of training those employees tasked with performing service and maintenance (called LOTO authorized employees), they often forget to train other employees covered by the standard. OSHA expects employers to provide training to employees who operate the equipment being serviced and to anyone else who may be present in areas where LOTO may be applied.

To satisfy the LOTO standard, she says training should ensure affected and other employees understand the purpose and function of the energy control program and procedures, know when the procedures are being used, and to be aware of the prohibition against attempting to restart a machine that is locked out.

Employers also often overlook the importance of training temporary workers before exposing them to workplace safety and health hazards. “If it is necessary to assign temporary workers to perform service or maintenance tasks, it is essential that those workers receive the same training given to permanent LOTO authorized employees,” editor stressed

She warns that, “Employers should never assume the staffing agency sending the temporary workers provided that training; instead, the host employer should trust and verify, or provide the training directly.” Even if the staffing agency provides training to temp workers, the host employer is presumed to have knowledge of unique, site-specific hazards, and is generally expected by OSHA to provide additional training specific to its workplace and equipment.

There is one more vital step employers need to take. To reduce the likelihood that OSHA will find fault with your company’s LOTO program, editor urges employers to proactively audit every aspect of their LOTO policies, practices and procedures, and seek advice from an expert safety consultant or experienced OSHA defense attorney, and then act quickly to correct any program deficiencies.


September 15, 2018
Your Lockout / Tagout Program There’s no way to write a policy that covers every possible lockout/tagout scenario. Discover how to create a balance between a program that is too restrictive and one that doesn’t go far enough to protect employees.

As the gavel slams down, the CEO of the medium-sized pharmaceutical company looks down in disbelief. They lost the case before the Supreme Court and now they have the tough task of rebuilding morale and their (obviously inadequate) lockout/tagout (LOTO) program. The judges determined that the company's non-compliant LOTO program was to blame when a large autoclave that was being serviced inadvertently was re-activated remotely by a control room operator, killing three workers.

The company has a new attitude towards safety now and a new safety budget. The board of directors determined that they were going to completely revamp their LOTO program in house, starting from the ground up. After such a horrific tragedy, everyone in the company — from management to line employees — is looking for answers. Not only about what happened, but more importantly, how can they ensure it never happens again.

When an accident of this magnitude occurs, the knee-jerk reaction by upper management is to button up their policy and restrictions so tight that they don't allow for the most important element in safety — the human element. Because there's no way to write a policy that covers every possible scenario that authorized employees will encounter, it's more effective to help teach and enforce an approved approach towards the likely scenarios that will be encountered in their facilities.


CIRCUMVENTING EXCUSES

The result of making a policy and program too restrictive: more accidents. When we give trainings around the country in different industries, we hear the same valid concerns brought up when we help implement the new LOTO program or come in to help after a program has been made too restrictive:

  • How can I be expected to lock it out when it needs to be partially energized to do my service work?
  • When I lubricate the chain right now, it takes me 5 minutes. If I have to lock it out each time I lubricate each part of the chain it now will now take me longer than an hour.
  • Our equipment jams up three to five times an hour and I have to clear these jams to keep product moving. It takes me less than 30 seconds to clear the jams right now, but if I have to lock it out each time, it will take hours and production will suffer greatly.

The list goes on, but the common theme is that authorized employees don't realize that the program implemented to save their lives is practical. And management does not do a good job of explaining the value of the LOTO program, simply saying, “Do it.” Then the employer realizes that they're paying a cost for the program and production is down or accidents are up or both.

So what is the answer? As a manager, how do you ensure your employees are safe without damaging the business? As an authorized employee, how do you get your job done safely without taking so long to do simple tasks?

The answer is simple: Allow employees to make decisions, but make sure the decisions are guided by a firm understanding of what is and isn't allowed.

It won't be the same, specific answer for every company or industry. OSHA provides guidelines in the regulation that must be followed and employers are expected to find a good fit for their business while staying within these parameters.


SOLUTIONS

Here are some solutions that might surface from an authorized employee working under a high-performance, employee-driven LOTO program:

Partial energization: Tom, an authorized employee, realizes that to program the robot properly, he needs to be inside the guarding and very close to the robot and part. He remembers from the company policy and training that he can perform this task if he ensures he has the equivalent level of safety that a full lockout would provide. Since this service only is related to training the robot, he ensures he has the only control pendent and thus full control of starting/stopping the robot. He now can safely and legally be inside the guarding and close to the equipment while conducting this task.

While programming the robot, Tom realizes that there is an air leak on the lower robot support arm. To fix this leak, he would have to shut off the upstream air and replace the leaky fitting. He knows from company policy and training that if he's performing non-routine maintenance, he must lock it out, so he follows the machine-specific LOTO procedure posted on the equipment and brings the robot down to zero energy state within minutes to safely perform this task. The entire task took less than 30 minutes and he knows this is the preferred company methodology to keep him safe.

Minor Maintenance: Mark, an authorized employee, returns to work after annual refresher training to perform a simple task of lubricating a long chain on a product conveyor. This task previously only took him 5 minutes because he wiped the lubricant on as the chain was moving. But he learned in training that if you remove guards or put your hands in the moving path of the equipment, you must lock it out.

Mark knew locking it out wasn't practical. His training instructed him to make management aware of such issues, so he brought it up to his safety manager and they worked out an alternative: They modified the guard to have an opening so that a lubricant extension rod could be inserted while the chain was moving to lubricate it just as efficiently as before. Using tools to keep your distance will allow you to safely avoid a lockout entirely.

Clearing a jam: Anita, an operator of the equipment and an authorized employee, was in charge of running a large case packer. From time to time, the cardboard boxes would jam before they were filled, causing the equipment to stop. To clear the jam in the past, she would just hit the e-stop button and grab the boxes that were jammed and get the equipment running in less than 30 seconds.

The equipment was designed to allow this to be done safely, but after her training, she discovered she was placing her body in harm's way every time she cleared a box. Even though the equipment wouldn't move while the task was being performed, she was not in control of the equipment — she needed to lock it out. Locking out all four disconnects each time it jammed would cause the company to lose a lot of money in production, but she didn't know how else to do it. After trying to use a tool to clear the jam, it became obvious that she needed to clear the box with her hands. A customized machine-control procedure was developed for clearing the frequent jams on the equipment. After extensive analysis, it was determined that turning off and applying a lock to the local electrical disconnect provided an equivalent level of safety as a full LOTO for that specific task. They also took it a step further by permanently fixing a lock near the disconnect so that it only took her 20 seconds to lock out the main electrical and attempt to restart to verify it was in fact inoperable. Then she could safely clear the jam and return the equipment to full service in a matter of less than 1 minute.

To truly get the most from your LOTO program, authorized employees must be taught how and when to lock out the equipment and also what to do when they encounter something out of the ordinary. A high-performance LOTO program is designed to change and update as the workplace changes. With employee involvement, these changes and updates will occur organically and be much more practical than if it all fell on the safety manager's shoulders.

A policy that is too restrictive only will lead to more accidents because employees will invent shortcuts to get the job done, or they will follow the policy as written and production may drop so dramatically that it will be difficult to stay in business.

With a good understanding of the regulation's intent, a LOTO program can enhance production and, more importantly, keep everyone safe.

Contact E-Square for help you in designing the practical LOTO policy for your company – call : Lakshmi : 0091 8800187868


September 12, 2018
Controlling Hazardous Energy with Lockout/Tagout (LOTO) Do you know, that (as per the recent surveys done worldwide) only about 10 % of companies run effective lockout programs.

During the Industrial Revolution, workers began to specialize in operating and maintaining machinery and quickly, consequences occurred : Those workers were increasingly injured or killed while servicing this equipment. This spurred improvement in the design of machinery to shield people from the dangerous work they performed.

The early efforts of the National Safety Council and similar organizations to raise awareness of the importance of machine guarding reduced the rate of accidents that were suffered while machinery was operating. But when these machine guards were removed to repair or service that equipment, a disturbingly high number of incidents continued to take place as equipment suddenly started up or released dangerous flows of energy, taking operators and other personnel by surprise.

The American National Standards Institute (ANSI) began looking at these causes of injuries and fatalities in the 1970s and published its first guidance on controlling hazardous energy with the practice of lockout or tagout in 1982.

The ANSI Z244.1 lockout standard became the inspiration for the OSHA regulation of 1989 requiring employers to put procedures in place to protect their workers by fully isolating machinery from the energy sources that drive them.

Despite the requirements of OSHA 29 CFR 1910.147 and other related federal and state regulations, incidents continue to occur at a pace that makes violations of the lockout/tagout requirements perennially one of OSHA’s most frequently cited regulations, as well as one of the costliest.


What Makes Lockout Compliance So Difficult?

Twenty-eight years after the OSHA lockout regulation went into effect, the law remains one of the most challenging for employers to successfully facilitate in their workplaces. It has been found that only about 10 percent of companies run effective lockout programs – defined as meeting or exceeding compliance requirements with lockout being practiced routinely each time it is indicated by the hazards of the tasks being performed.

Most of the companies are at the initial stages of encouraging their employees to apply lockout when needed or improving the regularity of protecting themselves. Any time a company can pursue proactive, continuous improvement on a controlled timeframe, rather than as a reaction to a crisis, it is substantially beneficial to their bottom line and sustained profitability. This is where we “E-Square” – come in to picture to provide the best of the LOTO products and services for successful implementation of Lockout/Tagout.

Often only select authorized personnel receive the training and other resources to use lockout to protect themselves. Yet the need to apply lockout comes up frequently. It can be complicated by time considerations, insufficient numbers of trained personnel with access to accurate procedures describing primary and residual energy control measures, as well as the lack of quick access to safety equipment used to secure energy isolation devices, such as switches and valves. When we combine those factors with the challenge that sometimes energy sources must remain on to perform certain tasks, the variables combine to create confusing and conflicting messages to those tasked to maintain equipment. As a result, many managers and their workers believe lockout can impede productivity. But with right attitude and policies, this myth can be overcome, E-Square can help you in this.

For the latest in best practice guidance on the control of hazardous energy sources, the ANSI/ASSE Z244.1 (2016) standard was updated extensively and provides the latest methodology and technological practices in a highly usable format that explains how to improve the facilitation of lockout, tagout, and alternative methods to control hazardous energy sources. Z244.1 (2016) is a must read for anyone seeking to improve their practice of locking out energy-related hazards.


So, Where Should You Start?

A common challenge companies face when seeking to begin or improve the use of lockout to protect their workforce is where to start. From the emphasis provided in Z244.1, the best way to begin is to contact E-Square and its professional team of LOTO engineers will help you in drafting a written plan of the lockout practices needed to achieve compliance - and then go beyond. A well-written lockout program serves as a user-friendly guide to implementation. It is also a benchmark for checking how lockout is really being performed, as compared to how it was planned to be applied. This is the time when you can contact E-Square LOTO Professional - who have experience in establishing effective lockout systems.

Levels of Authorized Training

  • Machine operators and set-up specialists should focus on the basic practices of the company LOTO program with emphasis given to hands-on training with the limited number of machines they routinely work with.
  • Supervisors can benefit from a more in-depth knowledge of the management responsibilities of the company energy control program and how to coach successful behaviors. They need more general knowledge on how a wider range of machinery under their oversight needs to be properly isolated and secured.
  • Maintenance personnel often need much broader lockout training because they can be expected to deal with most, if not all, of the equipment under the company's roof.
  • Electrically qualified personnel have special requirements for lockout identified in OSHA Subpart S.

Does Lockout Impact Efficiency?

Three things are at the root cause of inefficiency when it comes to routinely and properly applying lockout/tagout.

1. Absence of knowledge. If workers don't understand what could hurt them and the circumstances that could lead to unexpected startup, they can't appreciate the value of protecting themselves. They need good training and the guidance provided by accurate machine-specific lockout procedures to know how and why to protect themselves.

2. If the culture of the workplace is to do whatever is necessary to get the job done, workers must decide in each situation whether the time to apply lockout is justified. Unfortunately, the statistics support they often make the wrong decision, taking dangerous shortcuts. It has been observed that the more practiced a worker is with the skill set of lockout, the faster and more consistently he will apply it. It becomes the normal way to perform a task and is done consistently the right way.

3. Lack of necessary resources. If lockout procedures are not readily available to reference or hands-on, machine-specific training is not provided, errors are very likely to be made. When all of the needed lockout equipment are not immediately available, chances are workers will think twice about going to get the safety devices and locks required for the task. If there's insufficient lockout resources or guidance from company leaders, employees may believe that unsafe behaviors are tolerated, if not encouraged.

The severity and related costs of lockout-related accidents are undeniably high. When these root causes are effectively addressed, protective practices flourish and are used frequently. They become the rehearsed and routine way of performing maintenance, repairs, cleaning, troubleshooting, and set-up activities.

When, for the first time - ANSI Lockout/Tagout Standard and the OSHA LOTO regulation came out in the eighties, there was a lack of lockable energy isolation devices and no aftermarket lockout devices to add lockability to equipment of that era. Alternative methods to lockout were poorly understood and usually undocumented. These days, virtually every type of machinery, including those from foreign sources, is much more likely to be equipped for lockability or can easily be retrofitted with effective aftermarket lockout devices. Alternative procedures involving partial lockout and additional control methods can be successful at providing a safe way of completing tasks when energy must be present.

Getting companies and their workers engaged in a best-practice approach to using lockout to control hazardous sources of energy is all about planning, implementation, and a culture that believes working safety is more than a sound business decision. It's ( LOTO) a way of life.


September 8, 2018
Take a continuous improvement approach to Lockout / Tagout by proper / regular trainings If yours is a workplace where lockout/tagout procedures are part of daily exercises, you’ll want to be mindful that they don’t become secondary considerations ever.

These elements — which as noted by OSHA speak to practices and procedures necessary to disable machinery or equipment so as to prevent the release of hazardous energy while employees perform service and maintenance activities — should be reinforced regularly.

We at E-Square, make sure that, while conducting lockout/tagout training to your authorized employees, we shall cover all of the standard’s requirements and your employees shall be thorough about,

  • The recognition of applicable hazardous energy sources
  • The type and magnitude of the energy available in the workplace
  • The methods and means necessary for energy isolation and control
  • Tagout system limitations

And, also told them all about how to use written lockout/tagout procedures.

Ultimately, though, there comes a time when you can ask for a refresher training, and when you do that, you have an opportunity to improve the program.


Check the written procedures

Mechanics and maintenance teams can work on dozens of machines in your facility. Sure, each machine has its own unique, descriptive lockout/tagout procedure, but have the mechanics read the procedures for each of the machines they work on? Do they follow them? Are the written procedures a help or a hindrance to the people who need to use them?

For lockout/tagout refresher training, we work with your authorized employees to go through the details of the lockout/tagout procedures and make them simplified so that they can be easily understood and used accordingly to save precious lives of workers..


Start with what’s important

We target the refresher training to areas that are important to the authorized employees.

We ask them, if they are unsure about any parts of the procedures for any of the machines or equipment they service.

We schedule a training session, and meet the operators at the machine. Have the mechanics show us the part of the procedure that is unclear. We work with them to explain the procedure. During the session we do not hesitate to call in an expert (electrician, engineer, etc.) If necessary, we revise the written procedure until it’s easier to understand.

This same kind of thorough, machine-specific refresher training also needs to be done when machines and equipment are moved or new machines are introduced on the shop floor.


Be user-friendly

We emphasize that the written procedures to be accurate and easy to use. If our customers veteran mechanics are having problems with a procedure, we correct them before contractors or new employees rely on them.

Our engineers are very open to suggestions for adding illustrations or changing the format of the written procedures. Every detail is worked out professionally and even we provide labels on the machine for help.

Trained and informed authorized employees keep your lockout/tagout program alive. Involving them in reviews of lockout/tagout procedures recognizes them as being the authorities that they are.

Contact Info

E-Square Alliance Pvt. Ltd.

  • 512, New Delhi House, Barakhamba Road, New Delhi - 110001, INDIA
  • (00 91) 11 6632 2665 / 2371 7868 / 2332 7868
  • lotowala@gmail.com / loto@vsnl.net
  • +91 9811 076 259
  • +91 8527 685 685 (Mr. Sanjay)

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