Page 51 - Occupational Health & Safety, March 2017

The importance of a well thought out and documented lockout program is broadened by the additional information provided in Section 6.
exposures. We consider these engineering controls potentially to be an improvement over the procedural measures provided by the behavior-reliant application of lock- out techniques to significantly reduce the likelihood of human error. The new ANSI standard provides detailed guidance on if, when, and how a wide range of alternative control methods can be applied to result in equal or improved protection for people performing specific tasks.
Additionally, the new Z244.1 Standard offers more than two dozen informational Annexes that provide examples of risk as- sessment techniques, sample policies and lockout/tagout procedures, group lockout guidance, and inspection information. Al- ternative risk reduction methodology is covered in detail specific to a number of new technologies, including the Packag- ing, Pharmaceutical, Plastics, Printing, and Steel Industries; Semiconductor and Ro- botic Applications; and others challenged by the current regulatory limitations.
The ANSI Z244.1 Committee strongly believes injuries and fatalities related to unexpected startup of machinery or release of hazardous energy are preventable while recognizing that zero risk is only a theoreti- cal possibility. Our newly revised standard provides the latest information on achiev- ing acceptable levels of risk by knowledge- ably applying conventional lockout/tagout or well-determined alternative methods to prevent these avoidable accidents from oc- curring.
Todd Grover is the Global Senior Manager for Applied Safety Solutions at The Master Lock Company. He has more than 30 years of experience as a practicing safety profes- sional and EHS manager. His experience with a wide range of industries has in- volved the preparation of numerous lockout policies and detailed procedures, company- specific compliance training, accident inves- tigations, and acting as the representation of many employers during OSHA citation cases. He is a participating member of the ANSI Z244.1 Committee on the Control of Hazardous Energy, a participating member of the ANSI Z10 Committee on Safety Man- agement Systems, as well as a delegate to the U.S. PC 283 committee contributing to the upcoming ISO 45001 Global Standard for Occupational Health & Safety. Contact him via email, tgrover@mlock.com, or by phone at 414-571-5625.
tions in new machinery construction has resulted in a heightened capability for it to be dependably controlled during servicing operations. This section provides guidance on roles and responsibilities of suppliers and builders to design for integral lockabil- ity, tamper resistance, and the use of con- trol reliable safeguarding technology when applicable. Suppliers are compelled by the standard to document safety systems, pro- vide risk assessments, and offer procedures that justify alternative methods of protec- tion and how exposures can be minimized during routine and repetitive servicing, re- pair, and maintenance activities.
This results in end users being better prepared to finalize their own safe work procedures for personnel operating the equipment. Machinery builders are en- couraged to use the tenets of Section 5 to enhance the value of their product offer- ings to customers who are looking for en- gineering safeguards and information to be part of their purchase considerations. End users purchasing new or modified equipment also can use the guidance in Section 5 in bid specifications to make sure equipment is designed to be readily isolated, securable, and ready to be ser- viced safely and efficiently.
Section 6—The Hazardous Energy Control Program
The importance of a well thought out and documented lockout program is broadened by the additional information provided in Section 6. Information on managing change for new or modified equipment in the work- place and methods of timely updating and document control are noteworthy additions. This ensures analysis is performed prior to startup to allow for proper engineering and personnel preparation. Also of benefit are new or revised operating procedures, main- tenance requirements, lockout instructions, training information, and tasks that may re- quire alternative procedures.
Section 7—Control of Hazardous Energy
This section has been expanded significant- ly to discuss improved hazardous energy control procedures, the identification of en-
ergy isolating devices, verification by test- ing of the effectiveness of de-energization, as well as new provisions for interrupting energy isolation for positioning and test- ing requirements. More information is also offered on protective hardware and tags, including the use of warning placards, as well as complex group lockout practices and transfer of responsibility between work shifts, including the use of transfer locks. Guidance in working with contractors is also thoroughly detailed.
Section 8—Alternative Methods
A major effort was made in this section to expand guidance beyond OSHA’s limi- tation to tasks that are routine, repetitive, and integral to production operations. The committee recognized that there are also many maintenance, repair, or service work assignments where energy may need to be present to perform the job properly, which do not allow for the full application of isola- tion and lockout. We held that competent evaluation methods completed specific to the task being performed is the best meth- od of determining the feasibility of apply- ing lockout or justifying dependable alter- native methods to lockout.
Let me reflect the Z244 Committee’s position clearly. Lockout shall be used un- less the user can demonstrate that a well- established alternative method will provide effective protection. In situations where the task is not well understood or risk assessed, lockout shall be the default protective measure applied to control machinery or processes. Section 8 specifies that alterna- tive methods shall be used only after haz- ards have been assessed and documented through the application of a Practicabil- ity (or Justification) Study. This results in a “Go/No Go” decision as to whether a risk assessment is reasonable to perform as the next step.
With a decision to move forward, a risk assessment process is completed to deter- mine and demonstrate that the techniques used will result in negligible risk of sudden startup. These assessments detail control measures that determine whether reliance can be placed on technically reliable safe- guarding methods to engineer out hazard
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