Employer Responsibility: The employer must conduct a pre-LOTO work survey. “Before work is begun the employer shall ascertain by inquiry or direct observation, or by instruments, whether any part of an energized electric power circuit, exposed or concealed, is so located that the performance of the work may bring any person, tool, or machine into physical or electrical contact with the electric power circuit.” 1926.416(a)(3)
The employer must provide training and develop effective LOTO procedures. “The employer shall advise (train) employees of the location of such lines, the hazards involved, and the protective measures (procedures) to be taken.” 1926.416(a)(3)
The employer must provide training and develop LOTO procedures for chemicals as well. “Employees required to handle or use flammable liquids, gases, or toxic materials shall be instructed in the safe handling and use of these materials…” 1926.21(5). The Right-To-Know Act and the Hazard Communications Standard 1910.1200 also require training and procedures.
Purpose: OSHA’s construction standards tell you what to do, but not how to do it! This following training outline and procedure tell the how to do construction LOTO. It consists of the 1926 requirements and general construction practices necessary to meet your responsibilities. These procedures establish the minimum construction requirements for the lockout of energy isolating devices. It shall be used to ensure equipment is isolated from all potentially hazardous energy (chemical or electrical or whatever), and locked and tagged out before employees perform any servicing where the unexpected energization, start-up, or release of stored energy could cause injury.
Responsibility: Employees shall be instructed in this procedure. Each new or transferred individual and other employees whose work operations are or may be in the area shall be instructed in the purpose and use of the lockout and tagout procedure during initial orientation training.
Basic Rules for Using Lockout/Tagout Procedures: All equipment shall be locked out or tagged out to protect against accidental or inadvertent operation when such operation could cause injury to employees.
The Prime Contractor or employer shall provide locks and no other locks shall be used for lockout. (Common Law, the courts have ruled that locks are PPE and the employer must provide PPE for it’s employees.)
Employees will not attempt to operate any switch, valve, or other energy-isolating device when it is locked or tagged out.
Only trained employees shall utilize Lock and Tag Outs. (1926.209(b)(4) and 1926.416(a)(3))
Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of lockout protection. This includes a provision for the orderly transfer of these devices between off-going and on-coming supervisors, to minimize exposure to hazards from the unexpected energization, start-up, or release of stored energy from machines or equipment. On-coming supervisors shall be required to “lock-on” before the off-going supervisor will “lock-off.” Where the machine or equipment is out of service for an extended period of time, there is no requirement to transfer the locks and tags during each shift change.
Work only under your locks – not someone else’s!
NOTE: Machines or other equipment, using a simple wall plug as the power source, are not included as long as the plug is controlled by the supervisor or operator. If necessary a plug lock will be provided.
Sequence of Lockout Procedure: Contact the designated LOTO person for permission to conduct the lockout. This designated person must conduct a LOTO work survey to determine what measures are needed. 1926.416(a)(3)
Notify all affected employees that a lockout is going to be utilized and the reason.
If the equipment is engergized, shut it down by the normal stopping procedure (depress stop button, open toggle switch, etc.).
Dissipate or restrain stored energy (such as that in springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc.) by methods such as repositioning, blocking, bleeding down, etc.
Lockout, isolate, or render inoperative ALL the energy isolating devices (switches, valves, or other energy isolating devices) methods include locks, tags, chains, cables, wedges, blanks, or other additional safety measures (1926.950(d)(ii)(a) and 1926.417). If you are unsure of how to apply a LOTO device; contact your foreman, if that fails then contact the designated LOTO person for direction. If equipment is rendered inoperative without the use of a lock – it must be tagged.
Isolation procedures include such means as: Blanking and blinding: Blanks when installed, shall be of a compatible metal with the chemicals in line and of sufficient strength to withstand the maximum pressures that could be exerted against it. Double-block and bleed, line breaking or misalignment, and locking out valves. Test for leaks with a monitoring device if toxic, explosive, or flammable substances are a concern (required by HAZ COM, 1926.33, and 1926.55).
Some breaker switches (and other equipment) can’t be locked out. OSHA requires equipment or circuits to be rendered inoperative (1926.417(b)). Remove the breaker wires from the breaker and the wire screws. Tagout the ends of the wires and shield wiring if hot (wire nuts).
When underground facilities are exposed (electric, gas, water, telephone, etc.) they shall be protected as necessary to avoid damage. 1926.956( c)(3)
Where multiple cables exist in an excavation (underground), cables other than the one being worked on shall be protected as necessary. 1926.956( c)(4)
When multiple cables exist in an excavation, the cable to be worked on shall be identified by electrical means unless its identity is obvious by reason of distinctive appearance. 1926.956( c)(5)
Before cutting into a cable or opening a splice, the cable shall be identified and verified to be the proper cable. 1926.956( c)(6)
When working on buried cable or on cable in manholes, metallic sheath continuity shall be maintained by bonding across the opening or by equivalent means. 1926.956( c)(7)
Tags must be placed on all locks and the tag must be filled out with the employee(s) name and organization. 1926.417
If the servicing process exposes employees to mechanical, electrical (50 volts + 1926.403(i)(2)), or other hazardous parts; Guards or barriers with caution signs (1926.200 and 1926.409(a)(3)) shall be erected to protect employee(s) from such contact. (ref: 1926.416 (a)(1) and 1926.958(c ). OSHA defines guarded as covered, fenced, enclosed, barrier rails, screens, mats, or other. Barrier is defined as a physical obstruction such tapes, cones intended to warn and limit access to a hazardous area.
OSHA requires verification of lockout (visual inspection or tests). After ensuring that no employees are exposed, and to check on having disconnected the energy sources, operate the push button or other normal operating controls to make certain the equipment will not operate. Some lockouts on this site can’t be checked with this method (wires). Use a meter (multi-meter) to ensure the device is not hot. (1926.950(d)(iii), 1926.416(a)(3), and 1926.954(d))
For equipment operating at 600 volts plus that can not be rendered open or locked require the use of protective grounds. (ref:1926.950(d)(1)(iv))
..1926.954(e) Attaching grounds.
(e)(1) When attaching grounds, the ground end shall be attached first, and the other end shall be attached and removed by means of insulated tools or other suitable devices.
(e)(2) When removing grounds, the grounding device shall first be removed from the line or equipment using insulating tools or other suitable devices.
(f) Grounds shall be placed between work location and all sources of energy and as close as practicable to the work location, or grounds shall be placed at the work location. If work is to be performed at more than one location in a line section, the line section must be grounded and short circuited at one location in the line section and the conductor to be worked on shall be grounded at each work location.
The equipment is now deenergized (locked out). Perform the work required.
Restoring Equipment to Normal Operations: After the servicing or maintenance is complete and equipment is ready for normal operations (if it is to be energized).
Notify affected employees and the designated LOTO person that the lockouts will be removed.
After all tools have been removed from the equipment, guards have been reinstalled, and employees are in the clear, remove all lockout devices, protective grounds, and remove barriers/signs erected to protect employees from contact with hazardous parts.
Operate the energy isolating devices to restore energy to the equipment (if required).
Procedure Involving More Than One Person: Two systems for lockout can be used, individual lockout and the lockbox.
Individual Lockout: Each employee shall place his or her own personal lockout device on the energy isolating devices (each employee does the LOTO sequence). When an energy-isolating device cannot accept multiple locks or tags, a multiple lockout device (hasp or tree) may be used. The last employee removing their lock or the designated LOTO Person assumes the responsibility for conducting the “Restoring Equipment to Normal Operations” procedure.
Lock boxes: The LOTO designated person will place lockouts on all energy isolating devices and place the lock key(s) inside the lock box. No extra or back-up keys for these locks can be kept. This designated individual assumes the responsibility for conducting the above procedures (Sequence of Lockout Procedure and Restoring Equipment to Normal Operations). Each employee in the workcrew will personally verify (by initialing the tags) that each energy device(s) is locked out (Common Law). Then the employees will place their personal lock on the box. The lockout keys can not be removed from the lock box until each employee removes their personal lock. The personal lock key is kept by the individual employee.
Emergency Removal of Locks: Verification by the employer that the employee [who applied the device] is not on site; All reasonable efforts to contact the employee to inform him or her that the lock will or has been removed and the employee is definitely informed of the removal of the lock upon his or her return to work. All employees who have locks applied for more than one shift; will recheck their locks before beginning work on locked out equipment.
Disclaimer: This procedure can’t cover all possible LOTO situations – no procedure can! If additional measures are necessary; each Contractor, Steward, Foreman, Supervisor, and Individual will take the necessary action to ensure the safety of employees!
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