Almost every compliance audit we do results in findings related to lockout/tagout (LOTO). We're not alone--in fiscal 2013, citations against the hazardous energy control standard (29 CFR 1910.147) were number 8 on OSHA's Top 10 list.

 

Most problems stem, at least in part, from a misunderstanding of OSHA's requirements under the LOTO standard. The most common issues we see include the following:

• lack of machine-specific (or machine group) LOTO procedures;
• failure to consider all types of hazardous energy, such as stored air or hydraulic pressure or mechanical energy;
• failure to perform annual inspections of machine-specific (or group) procedures;
• inadequate inspection methods (for example, inspections don't require one or more authorized employee to observe another authorized employee work through and test the LOTO procedure, or inspections don't require all authorized employees to participate in the inspection program);
• misapplication of the minor servicing exception;
• use of LOTO locks for non-LOTO purposes, such as for out-of-service equipment.

Fortunately, OSHA has provided very clear guidance on its expectations for hazardous energy control programs. The Compliance Directive CPL 02-00-147, available at https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-147.pdf, provides details on how OSHA expects employers to set up and manage their LOTO programs. OSHA also provides guidance and case studies through its Interactive Training web pages at https://www.osha.gov/dts/osta/lototraining/index.html.

 

In addition, STC will be providing a free webinar on how to implement an effective LOTO program on January 29, 2014. A registration link for this webinar can be found in this newsletter -  see Opportunities for Learning.

 

 

Barbara Jo Ruble, QEP, CPEA is the President of Specialty Technical Consultants. She has more than 30 years of experience helping clients in a wide variety of industries to develop, assess, and improve their EHS management systems and compliance programs. Barb has performed more than 200 EHS compliance audits or management systems assessments of industrial facilities worldwide. She has also provided independent review of corporate EHS auditing programs. Barb is the primary author of OHSAS 18001/OSHA-VPP Occupational Health & Safety Management Systems: A Complete Implementation Guide, published by Specialty Technical Publishers of Vancouver, Canada.

 

For more information about STC's EHS auditing services or to discuss this article, contact Barb at bruble@stcenv.com or at 410-625-1952.