Lockout/Tagout Compliance From ESC Services

Filed under ESC News, Resources
Federal regulation requires that companies create and maintain lockout/tagout programs to prevent accidents. Many companies are still unaware that they are not compliant until it is too late. - Jimi Michalscheck

Achieve Lockout/Tagout Compliance With Modern Tools and Solutions from ESC.

ESC Services, a Rockwell Automation Business, is here to help modernize lockout-tagout programs to adhere with OSHA compliance and integrate industry best practices.

Federal regulations require that companies create and maintain lockout/tagout programs to prevent accidents. Many companies are still unaware that they are not compliant until it is too late.

ESC Services takes pride in the core knowledge on matters of lockout/tagout compliance and unique sensitivity towards minimizing the impact lockout/tagout can have on your factory’s efficiency and productivity. ESC brings years of experience as well as state-of-the-art technology such as our award winning ScanESC solution to help improve understanding and implementation of proper lockout/tagout techniques.

Working with ESC means your company can stay focused on what it does best while allowing our expert engineers custom tailor and implement your hazardous energy control program in a turn-key fashion. While ESC’s solutions are engineered to exceed minimum compliance with federal and state regulations, the added benefits with our service comes with our comprehensive portfolio of services solutions that are focused on ROI (Return on Investment).

As the future trends towards smart assets and the Internet of Things converge in the factory setting, ESC helps future-proof your company by installing intelligent company-wide solutions that dynamically change with time as your needs and equipment change. Investing in lockout/tagout today may not only prevent costly fines, but also may improve your employee moral and boost productivity. Learn more about ESC’s advanced lockout/tagout solutions and how they can pay you back here.

When companies look to improve their productivity, often times safety is overlooked as one area that can be a gold mine for ROI. Some of the top areas to focus on for payback that require minimal investment revolve around the 5-components that are required for compliance – most notably, machine specific lockout/tagout procedures.

 

Graphical Lockout Procedure

 

 

The 5-components to lockout/tagout compliance are: 

Machine specific procedures for all serviceable equipment that resides on your site

Training for your people so they know how to use the procedures and for those who don’t use LOTO they need training on what LOTO is so they know not to touch it.

Devices, locks and tags to ensure you have the tools to lock any energy isolation point out after isolation.

Policy that amongst other things, ensures your employees know how to follow the rules as well as the penalties if they fail to follow the rules.

Auditing plan that ensures each procedure is inspected at least annually as well as ensuring each authorized employees is audited to ensure full understanding and competency with regards to lockout/tagout usage.

 

 

Best Practices – SOP (Standard Operating Procedures)

One of the easiest ways to uncover potential savings after your procedure upgrade is to look at the alternative means clause by OSHA.

From www.osha.gov – Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection

In other words, minor servicing on equipment is permitted (without lockout/tagout) as long as it’s routine and integral to the process and you have taken steps to ensure an equivalent level of protection is established as when lockout/tagout is used.

Most companies that are cited for lockout/tagout when trying to use this exception are cited because they fail to read and understand the part where it requires “effective protection”.

To give an example, let’s say your employee is working on a case packer that jams 2-3 times per hour. Your employee decides that this is routine and repetitive to unjam this packer so they begin using the guarding interlocks as the effective protection while entering this machine and unjamming the equipment. If this is the case, stop what they are doing now. If this activity (or similar) is being performed without equivalent level of protection as lockout/tagout for the specific task, it may lead to injury or death as well as a hefty OSHA fine.

Unless they are following a procedure (for instance a standard operating procedure, SOP) to take steps to ensure they are fully protected while performing this task then they are risking their life and limbs by entering the machine by simply opening the guard to clear the jam.

So how do you address minor servicing in your company? Simple – create alternate procedures that you have evaluated and tested to be safe for specific tasks. While these alternate procedures are not required by OSHA, you would have a document to prove that you created a safe procedure, trained to it, audited it and if someone is hurt you would have some way to check to see if they were hurt because they chose not to use these tools you have provided or if your tools failed. Without these documented alternate procedures, your company will be faced with a big OSHA fine as well as potential civil litigation from the incident.

SOPs are quite common and referenced in ANSI’s standard Z244.1 but they have no reference in OSHA’s federal regulation CFR 1910.147 or any other state OSHA standard. Why? Possibly because it would extend liability to OSHA if they created a standard by which they allowed alternate procedures to be used and someone was hurt. It’s also possible they are just currently too busy to add it to their lockout/tagout standard. While they do acknowledge it as beneficial, OSHA has no known intention to endorse it in the near future as minimum federal requirements.

 

No matter the reason, SOPs (or whatever your company might call them – machine control procedures, minor servicing procedures, etc) can be your silver bullet for productivity and safety. SOP task based alternative protection procedures allow your people to safety follow the approved steps for safe equipment control during minor service.

The moment someone is using an SOP as a machine control procedure to perform major maintenance (replace motors, large parts, etc) then you’re in violation of the standard and a full lockout/tagout procedure must be utilized to establish zero energy state.

Turn to ESC Services with your lockout and safety related needs. Contact us for more information today.

 

Quick Tip:

A quick and confidential way to calculate your potential cost savings (and potential risk) associated with lockout/tagout programs, visit our risk/reward calculator here: https://www.escservices.com/lockout-tagout-procedures/calculate-risk/

It only takes seconds and gives you immediate results.

 

 

 

About ESC Services
ESC Services, a Rockwell Automation brand, is a leader in lockout/tagout procedures. Our services include many aspects of employee safety and OSHA compliance, and our core focus is delivering custom comprehensive lockout/tagout service that yields intuitive graphical lockout/tagout procedures and modern methodology. Learn more about ESC Services here.