OSHA's requirement for "machine specific" LOTO procedures and the "exception"

Safety Info Posts - Lockout Tagout

Written by Bryan Haywood Wednesday, 11 September 2013 20:26
OSHA believes that because of the need to follow the steps in the energy control procedure carefully and specifically, and the number of variables involved in controlling hazardous energy, a documented procedure is necessary for most energy control situations. However, the Agency has determined that in certain limited situations, documentation of the procedure will not add markedly to the protection otherwise provided by the standard. These situations incorporate several common elements:

First, there is a single source of hazardous energy which can be easily identified and isolated, and there is no potential for stored or residual energy in the equipment. This greatly simplifies the procedure for controlling the energy, since the single energy source is all that needs to be isolated. Second, the isolation and locking out of that single energy source will totally deenergize and deactivate the machine or equipment. There are no collateral sources of energy which need to be addressed. Third, a full lockout of the energy source is achieved by a single lockout device which is under the exclusive control of the authorized employee performing the servicing or maintenance. As used in this provision, exclusive control means that the authorized employee is the only person who can affix or remove the device. The authorized employee follows all steps necessary for deenergizing the equipment, verifying the deenergization, performing the work, and reenergizing the equipment upon completion of servicing. Because the energy control elements are simple, with a single energy source being locked out and no other potential sources of unexpected activation or energization, the authorized employee can perform them without referring to a written document. Fourth, while the equipment is locked out, the servicing or maintenance cannot expose other employees to hazards. For example, shutdown and lockout of a conveyor cannot cause jams or other hazards at other conveyors which feed into the conveyor being serviced. So for the most part, OSHA requires the equipment the worker(s) is locking out to have an energy isolation procedure SPECIFIC to that machine or equipment. OSHA does permit "grouping like kind equipment" but that is covered in another one of my LOTO articles. The standard states: 1910.147(c)(4) Energy control procedure. 1910.147(c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locked-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or

reenergization of the machine or equipment during servicing or maintenance. It is the eight (8) items in the "exception" that I want to breakdown and discuss. (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees This is an easy test and being that it is condition #1, one would think that most equipment would not pass the very first test. For example, any machine or equipment that has an air (i.e. pneumatic) source of energy would NOT meet this condition. When we are dealing with an air source and we have the basic block valves that we are using as the isolation device, we will have Stored/Residual energy we will have to bleed off and take measures to ensure that it does NOT re-accumulate in the system. PLEASE understand that if your facility has effectively eliminated this issue by utilizing the specialized dump valves for plant air systems then the argument could be made the machine does not have stored/residual energy and re-accumulation is abated with this type of valve. But when we have the basic quarter turn ball valves on our plant air systems, merely closing the valve and applying a LOTO device to the valve (i.e. isolation device) does NOT bring the machine/equipment to a ZERO ENERGY STATE (ZES). We must take an extra step to bleed off the stored energy (air trapped) between the isolation device and the machine and then we may have to lock OPEN the bleed to ensure there is no "re-accumlation" of air pressure in the isolated system. (2) the machine or equipment has a single energy source which can be readily identified and isolated Man this is a loaded requirement in such a short sentence! So lets break it down: a) the machine or equipment has ONLY ONE energy source - so any machine or equipment that has two different types of energy (e.g. chemical mechanical, gravity, air, etc.) is ruled OUT, as well as if the machine or equipment has TWO (2) different feeds of the same type of energy but that requires two (2) different isolation devices. For example, the machine or equipment has multiple electrical energy sources fed through different isolation devices. b) the SINGLE energy source is "readily identified AND isolated" - can't put words into OSHA's mouth but most rational safety professionals would understand this to be the SINGLE energy source is electrical and there is a local disconnect on the machine or equipment. Keeping in mind this is the ONLY energy source as well. I guess the argument could be made for ANY single formof energy, as long as it has "no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees" (as stated in exception rule #1). (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment So far we have a machine or equipment that has a SINGLE energy source that "has no potential for stored or residual energy or reaccumulation of stored energy after shut down", and it's SINGLE energy source is "readily identified and isolated" in order to get the machine or equipment to ZES. (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance VERY basic stuff here, no need to breakdown. (5) a single lockout device will achieve a locked-out condition This one is pretty clear as well, but some over look the phrase "single lockout device". A "lockout device" is defined by OSHA as A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are

blank flanges and bolted slip blinds. So basically OSHA is saying that to get the machine or equipment to ZES we ONLY have to use "a single lockout device" (e.g. lock). I know we can manipulate the rules here and use a single lock on a Double Block and Bleed arrangement and claim we used "a single lockout device", but I think we can agree that OSHA's intent here is a VERY SIMPLE isolation involving ONE isolation device and ONE lockout device. (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance I often wonder why the hell OSHA stated "the obvious" then I am reminded what I consider "the obvious" is not so in many minds. This requirement is FUNDAMENTAL to LOTO practices, but unfortunately we still see this not being met in all type of isolations. So what OSHA is saying here is that the "lockout device" (e.g. lock) must be under the exclusive control of the worker doing the servicing or maintenance. Simply stated, the KEY TO THE LOCK MUST BE IN THE POCKET OF THE WORKER! Please note that OSHA did NOT state the "isolation device" but rather the "lockout device" which implies that a lock is placed on the isolation device. (7) the servicing or maintenance does not create hazards for other employees For example, the shutdown and lockout of a conveyor cannot cause jams or other hazards at other conveyors which feed into the conveyor being serviced. (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance. This one is pretty cut and dried. If the employer, in utilizing this exception, has an accident involving the machinery or equipment, in which the unexpected release of hazardous energy is a factor, this indicates the need for more formal treatment of the energy control procedure, and documentation then becomes necessary.
In closing, we need to understand that ALL EIGHT (8) items in the "exception" must be met in order to apply the exception. There are pieces of equipment and machines that would allow the use of the exception, but in reality they are FEW!

The exception is intended to apply to situations in which the procedure for deenergization, servicing, and reenergization can be carried out without detailed instructions of energy sources, machines, and employees. For example, a motor in a small machine shop is wired into a single electrical disconnect with no other energy source, and the motor does not present the hazards of stored or residual energy. When the motor needs repair, the authorized employee can isolate the motor from the single energy source and lock it out, using his/her personal lockout device on the disconnect, in accordance with the procedures set forth in the facility's LOTO program. Under these conditions, and provided that no other employees are exposed to hazards from the servicing operation, the servicing may be performed without the need to document the machine specific energy control procedure. When all of the conditions for the exception are met, the standard does not require the employer to document the energy control procedure.