Tuesday, April 1, 2014

Clarification of OSHA Requirement to Conduct Periodic Inspections of the Lockout Tagout Procedure

One side benefit of conducting numerous OSHA training classes and mock-OSHA inspections every year is that I get an opportunity to pick up on trends where employers and employees seem to be struggling to comply with certain OSHA standards. So in this month’s post, I want to discuss one specific part of OSHA’s standard for The Control of Hazardous Energy (also known as the Lockout/Tagout standard) where, more times than not, the requirements of the standard are not being met.
The specific section of the Lockout/Tagout (LOTO) standard I am referring to in this post is paragraph 1910.147(c)(6)(i), which requires employers to “conduct a periodic inspection of .  .  . 
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  1. I always believed it to be that we had to audit each Authorized person, not each equipment. Thank you so much for the clarification!

  2. One additional comment - while the CPL does allow "sampling" in large organizations, the periodic inspection requirement is really the assurance that you have a viable and effective lockout/tagout program - there's a lot of value in watching folks actually do work - and LOTO activities are the ones that can really make a difference in the safe accomplishment of the work. Think of the periodic inspection as a little added insurance in your operations....

  3. The range of machines and equipment needing control of hazardous energy safeguarding is incredibly diverse and enormous in terms of scope. In fact, the vision of this directive was to have a "one-stop-shop" that includes preamble language, interpretations, legal rulings, incident descriptions, key references ... Our approach was to integrate several energy control principles and practices together, such as LOTO, machine safeguarding, electrical LO & TAG, and other task-specific requirements so that the reader would better understand that it is really about protecting the worker from energy. As such, the 1990 directive's title was changed from LOTO to controlling hazardous energy.

    In terms of program maintenance, you possibly picked the single most important aspect of 1910.147 in this blog -- i.e., as procedures may be grouped (when they have similar control measures) and representatively sampled on a 12-month basis. I once audited a mill with 6,000 procedures and recommended LO (rather than TO) to provide better protection & also save on training & periodic inspection time (cost) as well as initiating this categorization and random group sampling methodology. Remember, retraining and other measures are still necessary when deviations or shortcomings are discovered.

    So many horrible outcomes have resulted from simple inaction like failing to control potential mechanical energy to more complex events involving hazardous chemical energy incidents that I wanted a thorough OSHA document addressing the subject (and not just the standard). In my biased opinion, reading this document is time well spent when developing and sustaining an occupational safety and health management program. Hope the OSHA CPL 02-00-147 helps people with protecting workers.

  4. Does anyone have any insight if a procedure is used less than once per year (i.e.: every two or three years).

    1. Paul.

      If you look at page 3-65 in the directive I referenced in this blog post, you will see this statement:

      "NOTE: Energy control procedures used less frequently than once a year (based on a twelve-month interval) need be inspected only when used."

      Hope this helps.

    2. A key element of the control of hazardous energy process is the TRY & CONFIRM isolation step. This may involve activating a switch, button or examining a gage(s), testing with an instrument and more to confirm isolation.

  5. We've got a client who was just told all the authorized users needs to be audited. That didn't sound right. Don't know how they would expect to get all the authorized employees anyway. That compliance directive you posted was very helpful. Thanks.


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