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LOTO

Lauren Smith

Updated July 18, 2019

Transcript

What is LOTO?

Proper lockout tagout tryout is achieved when all energy sources for a particular process, system, or piece of equipment have been isolated and the chance of unwanted or unexpected activation has been eliminated.
Improperly locking out is one of the greatest opportunities for severe injury.

Lockout Tagout Tryout

(OSHA 29 CFR 1910.147)

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Introduction

Proper Lockout Tagout Tryout is a crucial safety requirement.
Preventing the accidental release of hazardous energy ensures the safety of all employees.
Always follow Lockout Tagout Tryout procedures because your life and the lives of those working around you depend on it.

Common Pitfalls

Common pitfalls include…
Failure of all exposed workers to install a lock.
Failure to anticipate re-accumulation of energy.
Failure to establish specific tasks that require LOTO.
Failure to Lockout due to perceived feasibility issues, time constraints, etc.
Failure to distinguish between LOTO tasks and Minor Servicing tasks. Not understanding the difference.
Failure to use an acceptable energy isolating device.

Statistics

Lockout Tagout mishaps are generally severe!
Average lost work days for failure to Lockout equipment is 24 days per injury.
120 annual workplace fatalities are related to failure of Lockout Tagout.

Most frequently cited OSHA regulations

1. Fall Protection

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Powered Industrial Trucks

7. Ladders

8. Electrical – Wiring Methods

9. Machine Guarding

10. Electrical – General Requirements

Lockout Covers the...

Servicing and maintenance of machines when UNEXPECTED start-up or release of stored energy could cause injury.

OSHA Says...

At a minimum, you should receive the following training:
Understanding the basic purposes and procedures of the company’s Lockout Tagout Tryout program.
Understanding that “tagout” does not guarantee safety, and the reason why.
Periodic retraining particularly should your responsibilities change.
Additionally, we must conduct periodic inspections to make sure proper procedures are followed.

What does Lockout Mean?

Complete de-energization of a piece of equipment or machine through the use of mechanical energy isolating devices.
It should be noted that control circuits (PLCs, motor starters, emergency stops) are NOT energy isolating devices.

Lockout Responsibilites Q&A

Lockout Responsibilities

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Q&A 1

Q&A 2

Authorized VS. Affected Employees

Only authorized, trained employees may perform a lockout on a machine.
You are expected to understand how to control energy sources.
Affected employees are those employees whose job requires them to operate the machine or process on which maintenance or service is being performed.
Need to be notified upon shut down and start up.

When Do We Lockout?

Generally, ask yourself this question before performing any task.
“Can I be injured if the equipment starts unexpectedly?”

When Do We Lockout?

Continued

During servicing and/or maintenance of machines and equipment.
During normal production operations IF:
A guard or other safety device is bypassed or removed.
A body part is placed or has the potential to be placed in a point of operation or other danger zone.

What is Servicing and/or Mainenance?

OSHA says it is constructing, installing, setting-up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment.
These activities include lubrication, cleaning or unjamming, making adjustments and tool changes, where employees may be exposed to unexpected energization, start-up, or release of hazardous energy.

OSHA Exception on Lockouts

Minor tool changes, adjustments or other minor servicing activities which take place during normal production operations, if they are routine, repetitive, and integral to the use of the equipment for production…provided alternative measures are used that offer effective protection!

Alternative Measures of Protection

Shutting down the machine is not an alternative means of protection and does not protect the operator or other employees from normal production operation hazards because the machine or equipment can be easily turned on.
Alternative means may include: interlocked barrier guards, presence sensing devices, special tools, techniques or other safeguards which are under the exclusive control of the employee.

Sequence Locks

Also known as a keyed E-stops
May not be used in lieu of a hard lockout.
May be used if production operations meet OSHA exception (for production employees only).
Violations of this procedure will be investigated and handled as a Cardinal Safety Rule.

Lockout Procedures

Basic procedures shall cover the following elements in the following sequence:
Notify affected employee.
Shut down energized machinery.
Isolate energy source from machinery.
Apply lock and tag to isolation device.
Release any stored energy from machinery.
Try operating machinery using normal controls.

Procedures

Lockout Procedures

At CMC Steel...

At CMC Steel SC…
Tagout alone is not permitted. A mechanical hard locking system must be used to de-energize equipment.
That means all equipment must be modified to make a lockout possible.
In the event you identify a situation that does not allow this, report it to your supervisor.

Energy Control Procedures

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Procedures

Procedures need to include:
Specific statement of intended use of procedure.
Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control the hazardous energy.
Specific procedural steps for placement, removal, and transfer of lockout and tagout devices and the responsibility for them.
Specific requirements for testing a machine or equipment to determine and verify the effectiveness of energy control measures.

Where Can You Find the Procedures?

Where?

Lockout Equipment

Lockout devices must meet the following criteria:
Be able to withstand heat, cold, corrosion.
Same throughout workplace by color, size, and shape.
Strong enough to require heavy force or tools to open.
Identifiable by person who installs and removes it.

Lockout Equipment

Padlocks

Padlocks used at CMC Steel SC have the following distinctions.
Maintenance – Blue
Melt Shop – Gold
Roll Mill – Red
Shipping/Inventory – Red
Long Term – Purple
If Departmental Group Locks are to be used, they will be issued to the department by corresponding color.

Special Situations

Teams for large lockout jobs.
One member of the group has primary responsibility for procedures and safety.
Each member installs their own lock or tag.
Sometimes where work needs to be completed on the next shift.

Group Lockout

Same as individual lockout, except:
One member of the group has primary responsibility for procedures and safety of a set number of employees involved.
When more than one crew, craft, department, etc. is involved, lockout responsibility is given to one authorized employee for coordination.
Group Lockout Leader must determine exposure status of employees involved.
Each authorized employee attaches personal lock or tag to group lockout device, lockbox, etc. when they begin work.

Group Lockout

Each authorized employee must attach a personal lock with identification.
Each authorized employee must remove their lock when work stops.

Employee

Group Lockout

Video

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Group Lockout

Leader

Group Lockout Leader is responsible for appointing an authorized employee to VERIFY the equipment was locked out correctly. Verification process consists of ensuring the following:
All locks are properly placed on each piece of equipment.
All keys to corresponding equipment locks are placed in Group Lock Box.
Group Lockout Form is in a clear envelope with Group Lock Box.

Form

Shift Changes

Specific procedures are needed to ensure continuity of lockout/tagout protection, including provision for the orderly transfer of lockout devices between off-going and on-coming workers.

Long-Term Locks

Long Term Locks

Long term locks may not be used as an individual or group lock.
This has been implemented to ensure:
Lockout protection is continuous.
All employees can remove their locks at end of their shift.
When a long term lock is applied, individual locks must still be applied before starting work activities.

Long Term Locks

Checked Out

May be checked out for following reasons:
If authorized employee in getting off and no replacement is present to perform shift change.
If Group Lockout leader must leave plant but their replacement is not available for shift change.
When equipment is going to be locked out for multiple days.

Removing A Lock

Removing a Lock

If an employee is not available to remove a lock, we must:
Verify the employee is not in facility.
Make reasonable efforts to contact employee.
Inform employee of removal upon returning to work.
A member of management is only person who can authorize removal of a lock.
Any unauthorized removal of a lockout device will lead to corrective discipline up to and including termination.