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Steps for Temporary Removal and Re-energization During Lockout Tagout

dateOctober 12, 2021

An incident took place in March 2002. A California welder was asked to remove a jammed piece of metal from the hydraulic door of a scrap metal shredder by his supervisor. As the worker had done this several times before, he grabbed his ladder, torch, and padlock and went to the hopper.

While lying across the top edge of the door, he cut away the obstruction with the torch. Once he succeeded, though, the hydraulic door - which still was under pressure - closed upward on the man. He was crushed to death.

Two co-workers testified that the welder said he had secured the system, but the padlock he was supposed to use to lock out the system was recovered from his clothing.

The reason behind this incident?

Careless act of not applying proper Lockout Tagout. Such occurrences serve as graphic reminders that anytime you're dealing with equipment or machines powered by electricity, steam, hydraulics, gas, compressed air, or a combination of sources, always remember to follow prescribed Lockout Tagout (LOTO) procedures.

What Lockout Tagout Means?

The Occupational Safety and Health Administration (OSHA) LOTO standard (29 CFR1910.147) mandates criteria for de-energizing equipment during servicing and maintenance operations to prevent unexpected energization or start-up. Lockout refers literally to installing a lock (keyed or combination) on an energy-isolating device. Tagout refers to placing tags or labels on those devices to warn others not to restore energy to them.

Always remember one thing in mind, NEVER ASSUME!

To avoid an incident, never assume someone else has completed LOTO. You are responsible for your own safety. If you need to service any energized equipment or machine, you should always follow -

 Step-by-step LOTO Procedures:

  1. Locate and identify isolating devices to confirm switches, valves, or other energy-isolating devices for equipment LOTO.
  2. Notify all affected employees that lockout/tagout is going to occur. (Authorized employees must know the machine type, its energy magnitude, and the hazards.)
  3. Shut down the equipment/machine with normal stopping procedures.
  4. Isolate the equipment/machine from the energy sources by locking or tagging it out with assigned individual locks or tags. Only the worker completing the work will have control over the key.
  5. Bleed or release all potentially hazardous stored or residual energy, including trapped air, gas, and chemicals. Safely dissipate or restrain stored energy (such as that in springs and hydraulic systems) by repositioning, blocking, or bleeding.
  6. Verify equipment or machine isolation before servicing or maintenance work.
  7. Service equipment or machinery with a buddy, both wearing proper personal protective equipment (PPE) - insulated gloves, sleeves, insulated tools, and protective helmet as per the requirement.

Before lockout or tagout devices are removed and energy is restored, the authorized employee must always follow proper steps, like:

  1. Inspect the work area to ensure that nonessential items have been removed and that machine or equipment components are intact and can operate properly.
  2. Check the area around the machine or equipment to ensure that all employees have been positioned or removed safely.
  3. Notify affected employees immediately after removing locks or tags and before starting equipment or machines.
  4. Ensure that locks or tags are removed only by those authorized employees who have applied them.

Additional safety tasks are required for special circumstances, such as Testing or Repositioning equipment during servicing in situations involving, on-site contractors, or multiple shifts, or new equipment.

Where possible, equipment should normally be shut down and any residual / stored energy should be safely released. However, formal systems of work, such as a permit to work, are mostly required to safely manage high-risk maintenance operations. This makes the task time-consuming and lengthy.

In some special cases, like testing or repositioning, it may not be possible to apply Lockout Tagout during the test being performed. In such cases, OSHA permits the removal of Lockout Tagout devices and the re-energization of equipment only during the time necessary for the testing or positioning of the machine, equipment, or component, and only when re-energization is essential to accomplish the servicing task.

However, appropriate measures should be taken to protect people and minimise the risk in such special cases.

Temporary removal of locks or tags and re-energization of the machinery or equipment is permitted to allow testing or repositioning, provided that specific procedures control the sequence of actions to be taken. The procedures must provide maximum safety coverage for employees when the equipment or machinery must be energized during the course of servicing. Employee exposure to hazards is high during these transition periods.

When this occurs, re-energization also requires that the authorized employee:

  1. Clear the machines or equipment of tools and materials.
  2. Remove employees from the immediate area.
  3. Remove the LOTO devices as specified in your company plan.
  4. Energize and proceed with testing or positioning.
  5. De-energize all systems, isolate the machine or equipment from the energy source, and reapply lockout or tagout devices as specified.

Proper LOTO implementation is essential. According to OSHA, following proper procedures prevents approximately 120 fatalities and more than 28,000 lost workdays each year. Servicing carries risks, but when you take responsibility for your own safety, you can control those risks.

Companies spend millions of rupees to control such accidents and to be OSHA compliant but fail to recognize the exact reasons which are leading to continuous injuries and fatalities. Both, directly and indirectly, they impact the growth and stability of the company.

Legalities related to Lockout Tagout process vary from one country to another, and so do the penalties for any violations. While standard OSHA regulations are implemented worldwide, there are country-specific legal requirements that also need to be taken seriously. The cost of ignorance, indifference, and non-compliance can be much higher and much expensive due to heavy penalties and expensive fees on case suits. Following LOTO gives a sense of security, boosts morale and builds trust.

The company’s senior management needs to be committed to taking on the responsibility to manage health and safety as a key business risk and purchase the suggested LOTO products which offer high quality, durability, are easily identifiable, standardized and substantial. 

It is vital to develop and keep your lockout tagout procedures up to date, with timely training, retraining and inspections conducted. Including the above in the company’s LOTO PROGRAM is must and helps improve the competency of workforce and safety at your workplace. 

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.

E-Square Blog: Expert Analysis and Best Practices for Isolation Safety

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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