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Lockout or No Lockout: Navigating Equipment Safety Procedures

dateSeptember 06, 2022

In the intricate world of machinery maintenance and servicing, understanding when to utilize the Lockout Tagout (LOTO) procedure can make the difference between a safe operation and a catastrophic event. The nuanced distinction between minor and major activities plays a crucial role in deciding the implementation of this procedure. This article dives deep into distinguishing these activities and provides a comprehensive guide on when to deploy LOTO practices.

Delineating Activities: Minor vs. Major

Understanding the nature of the activity on the machinery determines the application of the LOTO procedure.

1. Minor Activities During Production:

  • Lubricating Parts: Ensuring seamless movement of components.
  • Cleaning Assembled Components: Preventing accumulation of dirt and ensuring effective operation.
  • Addressing Jams: Clearing obstructions for smooth operation.
  • Making Adjustments: Fine-tuning the machinery for optimal performance.

2. Major Activities During Service and Maintenance

  • Setting up Production: Preparing the machinery for operational efficiency.
  • Disassembly: Dismantling components for in-depth servicing or replacement.
  • Component Replacement: Exchanging faulty or worn-out parts.
  • Configuration Modifications: Altering machine setups to cater to new requirements or improvements.

While major activities invariably necessitate the application of LOTO, minor activities may not always require such stringent measures, as per OSHA guidelines.

OSHA's Stand on Minor Activities:
OSHA recognizes that some minor servicing activities, integral to production operations, may not require a full-blown LOTO procedure, given they are routine and repetitive. However, the caveat is that any alternative method adopted must ensure comprehensive protection against hazardous energy. It is thus imperative to consult OSHA's official guidelines and compliance documentation to discern whether an activity qualifies as minor servicing or not.

The Importance of an Energy Control Program:
The essence of LOTO lies in its ability to ensure worker safety during machine maintenance or servicing, especially when standard safeguards are compromised. The OSHA standard, 29 CFR 1910.147, delineates the minimum requirements for hazardous energy control, underscoring the necessity of LOTO especially when employees are exposed to such energy during servicing.

Yet, it's worth noting that if a safeguarding method effectively negates exposure to a machine's danger zone during servicing or maintenance, the stringent requirements of the LOTO standard may not apply.

Making Informed Decisions:
One of the prevalent challenges workers face is distinguishing between minor activities offering protection from hazardous energy and major activities exposing them to such risks. Such determinations are not mere academic exercises but are pivotal to worker safety.

Before embarking on any machinery-related task, it's essential to gauge the inherent risks. What may seem like routine cleaning might hold latent dangers. Incorporating comprehensive Risk Assessment (RA) and Job Safety Analysis (JSA) can illuminate potential hazards and recommend safe operational paths – with or without LOTO. Moreover, periodic trainings, audits, and reviews can further ensure compliance with safety standards and reduce risk exposure.

Deciphering whether to apply the Lockout Tagout procedure isn't always black and white. The intricacies involved require a thorough understanding, informed by standards such as those set by OSHA.

So, if you are still confused and looking for an answer to - To Lockout or Not to Lockout? Contact E-Square, Your No. 1 isolation safety partner!

E-Square Compliance and Education Division
About the Author

E-Square Compliance and Education Division

A team of safety professionals and educators united to enhance workplace safety with essential Lockout Tagout knowledge. We offer expertise to foster safety compliance and effective LOTO protocols across industries.

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The E-Square blog features advice, information and support on everything related to Lockout Tagout, including best practices, industry news, latest innovations and regulatory updates.


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