This OSHA Training blog is dedicated to enhancing knowledge of OSHA-related matters, especially in the areas of OSHA training and new/revised OSHA regulations.
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This OSHA Training blog is dedicated to enhancing knowledge of OSHA-related matters, especially in the areas of OSHA training and new/revised OSHA regulations.
I always believed it to be that we had to audit each Authorized person, not each equipment. Thank you so much for the clarification!
ReplyDeleteOne 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....
ReplyDeleteThe 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.
ReplyDeleteIn 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.
Walt. Did you (or do you still) work for federal OSHA?
DeleteDoes anyone have any insight if a procedure is used less than once per year (i.e.: every two or three years).
ReplyDeletePaul.
DeleteIf 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.
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.
DeleteWe'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.
ReplyDeleteWhen conducting the periodic Inspection on the energy control procedure, is there a special form or document needed for this?
ReplyDeleteYou just have to capture the information required by OSHA (identity of equipment, identity of authorized person(s) audited, name of auditor, and date). No particular form/document must be used.
DeleteJust wanted to say that this is a well-written explanation of what is most definitely confusing for many companies! Nice job!
ReplyDelete