Workplace safety is a top priority for any organization, and particularly so for warehouse and manufacturing facilities. OSHA’s lockout/tagout (LOTO) standard is well-known but it is less understood to which activities and protocol that standard actually applies. For instance, workplace procedures that are part of a normal business day are not regulated by LOTO standards. A worker operating a machine as part of her daily responsibilities is bound by OSHA’s 1910.212 machine guarding guidelines, not by LOTO.
When the machine needs to be powered down and cleaned or serviced, when a worker has to bypass a safety device and/or if a worker has to place himself in the machine (or part of the machine), then the lockout/tagout regulations come into play. LOTO is designed to protect the employees who are tasked with maintaining proprietary machinery as part of their regular duties. Often, companies will hone in on LOTO procedures for an unexpected release of electrical energy, while neglecting to include other types. Any time an employee could come into contact with unexpected energization or release of hazardous energy-whether that energy is mechanical, thermal or hydraulic–their company’s detailed lockout/tagout list must be followed.
Complicating matters is that, currently, LOTO standards do not apply in certain situations. The Federal Court of Appeals in 1996 ruled that energization is not unexpected if the employee had some type of visual or auditory warning beforehand; if the machine in question is very small or the controls are such that an employee would be fully aware if they re-engaged; or if the machine was unplugged and the worker had the plug in his/her sight. There have been court challenges to this ruling, and OSHA is pushing for a revision to the long-standing Standards Improvement Project, so it is critical that quality assurance executives stay up to date.