June 2009, Vol. 21, No.6
Hazardous Energy Control Procedures
After attending a local conference, I was perplexed. The speaker told the audience that every piece of equipment needs a lockout–tagout (LOTO) procedure. Do I really need to have a LOTO procedure on every piece of equipment?
The speaker was a salesperson for a popular software program that automatically generates procedures from some user input data and could have had a vested interest in making the requirements seem steep. As a safety practitioner, I was in disbelief that the requirement could be so stringent, so I wanted to do my own research.
According to occupational safety and health standards issued by the U.S. Occupational Safety and Health Administration, “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.”
This excerpt from 29 CFR 1910.147 (c)(4)(i) pretty much sums it up. In essence, the speaker I heard was correct from a certain point of view. However, there are a few exceptions. For example, similar equipment requires only one procedure. So, if a plant has six positive-displacement pumps of the same model, one procedure is enough.
The other exemptions are included in the table (below). Employers need not document required procedures for a particular machine or equipment when the listed exceptions are present. However, all of the exceptions must be in place — yes, all — in order to be exempt from writing a procedure.
The requirements of hazardous energy control are not as complicated as some perceive them to be; however, you may want to consult with a specialist before you determine whether you are exempt.
So, if you have to plan and schedule an undertaking as ubiquitous as developing an energy control procedure for every piece of equipment, how should you start?
First, the time to start is now.
Compile an inventory for all equipment that is serviced, maintained, adjusted, cleaned, replaced, repaired, or has a prime mover. Examples include pumps, valves, exhaust vents — pretty much anything with an on–off switch. Ask your inventory manager for a spreadsheet that may have equipment listed. If you don’t have an inventory, it will take you a week for a small plant (10 to 20 mgd [37,850 to 75,700 m3/d]) and a month for a large plant (100 mgd [378,500 m3/d]).
After you have achieved an accurate inventory, go through the list of exemptions. If you follow them step by step, you will more than likely find that not all of your equipment will be exempt.
This next step will be the most challenging. Choose a piece of equipment to write a procedure for, then find the authorized employee who has the most experience maintaining that equipment and the time to dedicate to developing an energy control procedure.
Have the employee walk you through the unwritten procedure he or she follows — and likely has followed for years — for that equipment. Write down each step and take a picture of the isolation area (disconnect) and where the lock and tag will be applied. This will make for easy reference when you write the procedure.
Plan to spend a long time with each equipment expert — this is where scheduling becomes a key benefit. To complete a procedure usually takes 4 hours. This includes time spent consulting with the authorized person, as well as writing the procedure.
Another way to generate LOTO procedures is to purchase software that will generate a procedure for you when you plug in some information and pictures. (The information usually includes pictures, hazardous energy types, the location of isolation points, and the type of isolation device [LOTO] to use.) Some software programs will even print a tag for you based on the procedure you created.
To find the right software for your need, consult your local safety equipment vendor.
Recently, I spent time at some Fortune 500 companies that have taken hazardous energy control to the next level. I was wowed by some of their innovations, including designing customized software products like the ones discussed above.
For example, Honda of America (HOA; Marysville, Ohio) has been a longtime leader in energy control and blazed trails in training and procedures. After reviewing their procedures, it occurred to me that the many wastewater facilities are just not doing enough. They may be doing enough to get by but not enough to ensure 100% safety.
Don’t get me wrong; I know you don’t have 32 robots on one piece of equipment, as HOA does. But you may have 32 steps that have to be taken in order to achieve 100% isolation or energy control.
One thing that I learned at HOA was that authorized employees hold the keys to success. They perform the procedures, so why not allow them the time to write the procedure and reward them for it?
We all have a lot to learn, including me. However, I believe understanding what we need to do and how to begin doing it will take us a step closer to reaching our own wow factor.
Tim Page–Bottorff is principal of Total Safety Compliance Co. (Mesa, Ariz.) and a member of the Water Environment Federation (Alexandria, Va.) Safety, Security, and Occupational Health Committee.
Exceptions to Energy Control Procedure Requirements
|1. The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shutdown that could endanger employees.||If you shut down the equipment and there is no potential for any stored energy, then you are exempt. A simple example would be a fully extended spring.|
|2. The machine or equipment has a single energy source that can be readily identified and isolated. ||Think of a spinning grinder wheel that is hard-wired. The isolation point is an on–off switch at the equipment.|
|3. The isolation and locking out of that energy source will completely de-energize and deactivate the machine or equipment.||This exemption is hard to meet. However, if you blank, bleed, and block a valve, the valve is exempt.|
|4. The machine or equipment is isolated from that energy source and locked out during servicing or maintenance.||You have to follow a six-step procedure that is typically understood as LOTO.|
|5. A single lockout device will achieve a lockout condition.||You don’t use more than one device. Gang hasps are prohibited.|
| 6. The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance.||The LOTO device is under control of the person working on the equipment.|
|7. The servicing or maintenance does not create hazards for other employees||This is self-explanatory. |
Adapted from U.S. Occupational safety and Health Administration occupational safety and health standards at 29 CFR 1910.147 (c)(4)(i).
LOTO = lockout–tagout.
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