"Lockout", "Tagout" among most Challenging Regulations to Interpret

Are Your Machinery & Equipment Lockout Procedures Fully Compliant?

This is a safety FYI about machine lockout on modern machinery and recognized alternative protection measures (APM’s). OSHA’s Control of Hazardous Energy standard, nicknamed Lockout and Tagout, have been among those OSHA regulations that are more challenging to fully interpret.   

Rusty Bolt

To introduce this discussion, I reference a few accidents and occasions where employers have received costly lockout violations. This includes a fatal injury investigation, another company that received $68,000 in citations, and one other, among the mix, a maintenance worker that was struck in his forehead by a ½’ bolt.  He was extremely lucky he fully recuperated with an odd scar he may tell his grandkids about.  

To the point:  In several cases the written procedures were inadequate leading to violations, despite the compliance efforts to produce them. They didn’t go far enough to address all of the hazards involved with setup, adjustments, tool changes, or more involved service work. Some companies have simply drafted procedures informing of shutting the machine off, affixing a lock and a tag, believing this is sufficient.  

For more complex or CNC machinery today, this doesn’t work for setup and adjustments to be made. Why? In many cases, a complete lockout of computer-controlled machinery makes such work impossible to do. A full lockout is likely required when significant work is required such as replacing and installing machine components; not for adjustments, tool changes, or other routine activities necessary. Be aware that if OSHA would investigate an injury involving any of this type of work, violations of the lockout standard will likely occur in the absence of adequate procedures, regardless of a clause in the standard addressing routine vs. non-routine activities.    

OSHA logoThe reference of APM’s in the written procedures, or provided elsewhere, may achieve satisfactory compliance.  This includes reference to information in the machine manufacturer’s operating and safety manuals.  This is a vital safety check!  OSHA investigations have included a review of these manuals with their enforcement efforts and also the applicable ANSI standards.  Part of the reason is that the OSHA standards on machine guarding are near 50 years old.  They successfully cite companies applying the ANSI standards and/or inconsistencies they find with recommended procedures in the operating manuals.  A key point: If there are inconsistencies with the manufacturer’s instructions and actual practices…re-assess this.        

Another aspect of lockout can be addressed referencing the example of the maintenance employee who was struck by the bolt. In this case the antiquated machine was locked out initially; but then re-energized for a brief diagnostic check without re-locking it out to continue with some further disassembly.  For appreciable service or repairs, a thorough pre-planning or task safety assessment is necessary that very likely is not included in the written lockout procedures. This assessment should factor all hazardous energy sources referenced in the lockout standard. 

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Ron Humphreys is an authorized OSHA Trainer and Safety Consultant for The Starr Group. He provides Risk Reduction Services to The Starr Group’s Customers.

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