What Does OSHA Want to See?
When developing a lockout-tagout program, the first consideration a facility must take into account is what machinery or equipment requires lockout/tagout procedures. OSHA Standard 1910.147 sets clear precedence for what qualities indicate that a machine needs a lockout procedure. Using these qualities, companies are expected to create lockout procedures specific to each machine relaying the specifications that will keep employees safe.
To determine the need for a lockout procedure, one must look at the energy sources present in the machine. OSHA decrees that any machine or piece of equipment that has two or more energy sources present must have a lockout procedure readily available. This regulation includes machines or equipment with any potential for stored or residual energy or re-accumulation of stored energy after shut down. Types of energy sources possible include: electricity, any product inlet/outlet, gas, pneumatic, water, and steam energy. Residual energies to consider are: magnetic, capacitance, gravity, spring, hydraulic, thermal and kinetic energy. If the machine or equipment contains any two or more of these energy sources a lockout/tagout procedure must be created and the information on these energies must be conveyed.
There are exceptions to this rule however. OSHA has set strict guidelines as to when a piece of equipment is exempt from having a lockout procedure. The machine or equipment must meet all of these criteria. The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist:
- The machine or equipment has no potential for stored or residual energy or re-accumulation of stored energy after shut down which could endanger employees
- The machine or equipment has a single energy source which can be readily identified and isolated;
- The isolation and locking out of that energy source will completely de-energize and deactivate the machine or equipment;
- The machine or equipment is isolated from that energy source and locked out during servicing or maintenance;
- A single lockout device will achieve a locked-out condition;
- The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
- The servicing or maintenance does not create hazards for other employees; and
- The employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.
If only one of these conditions is not met, OSHA considers the equipment to need a lockout procedure.
When OSHA inspects a lockout procedure, there are particular specifications that the procedure must contain in order to be considered compliant. The procedure’s intent to should be to contain the maximum amount of information on the lockout process so to prevent any injury. The information that OSHA deems necessary for the procedure to contain is:
- Type and magnitude of the energy that the machine or equipment utilizes.
- Hazards of the energy.
- Methods to control the energy.
- Type(s) and location(s) of machine or equipment operating controls.
- Stored or residual energy (such as that in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc.) and to it is to be dissipated or restrained by methods such as grounding, repositioning, blocking, bleeding down, etc.
- Type(s) and location(s) of energy isolating devices
Including these specifications into the lockout procedure is required. However, OSHA also wants to see a procedure that instructs the authorized employee on how to lockout a machine properly. OSHA provides a lockout sequence, that when followed, ensures that safety for the employee comes first.
If a machine or piece of equipment is in question, remember that the OSHA standard decrees that if it has two or more energy sources, or potential for stored energy, it must have a lockout/tagout procedure. These energy sources can vary but the lockout procedure must always contain specific information such as the type and magnitude of the energy, hazards of the energy sources and methods to control the energy. There are 8 criteria that a machine must meet in order be exempt from the lockout process. The piece of equipment must meet all 8 of this criterion to be considered an exception. Remember, that when it comes to safety, it is better to control all energy than take a chance of injury.