Page 39 - Occupational Health & Safety, December 2018

personnel changes. They must provide for the orderly transfer of lockout or tagout protection between employees as they are going off and coming on duty, it states.
The NORA Resource Guide
A new online resource from NIOSH is a step-by-step guide, the “Hazardous En- ergy Control (Lockout and Other Means) Resource Guide,” that offers sample materi- als and templates to help users implement the elements needed for successful LOTO program. Members from the National Oc- cupational Research Agenda Manufactur- ing Sector Council reviewed, adapted, and compiled the resources in it.
“It is a matter of life and death,” NIOSH noted on the page where the guide is post- ed. “Hazardous energy control is more than Lockout. It encompasses Machine Guard- ing, Alternative Measures (alternative guarding arrangement that prevents expo- sure to hazardous energy), Lockout, and other methods of ensuring worker safety from contact with hazardous energy.”
The guide2 covers four main activities needed for a successful program: energy control procedures; employee training; au- diting or conducting periodic inspections; and specifying, acquiring, or designing equipment that will accommodate lockout procedures. The four “work best when they are documented in the form of a written procedure,” the agency pointed out.
Significant Penalties
for LOTO Violations
Lockout/tagout ranked fifth on OSHA’s list of the Top Ten most-violated standards during fiscal year 2017. There were 2,877 violations of 1910.147 during that fiscal year, an OSHA Directorate of Enforce- ment official announced during the 2017 National Safety Council Congress & Expo. (During the 2018 Congress & Expo, OSHA announced that LOTO also ranked fifth in fiscal 2018, with 2,944 citations issued dur- ing that fiscal year.)
The agency frequently announces LOTO enforcement actions with large penalties:
■ OSHA announced an enforcement case with $107,168 in proposed penal- ties Oct. 1, 2018, against an Ohio plastics manufacturer that allegedly exposed em- ployees to amputation hazards. One ci- tation ($12,934 in penalties) alleges the company committed a serious violation by not ensuring periodic inspections of the
energy control procedure were conducted at least annually on three hydraulic presses, and that employees didn’t follow all steps required for control of hazardous energy before they changed dies in the presses.
Another citation in the case, with an identical penalty, alleges a serious violation of 29 CFR 1910.147(d) at the facility because the established procedure for application of energy control did not cover the actions list- ed in that section of the standard and were not done in sequence as it requires.
OSHA also cited the company for a re- peat violation, with $71,137 in penalties as- sessed, for not providing adequate training to ensure employees understood the pur- pose and function of the energy control pro- gram. OSHA had cited the company for the same violation once before, with the citation affirmed as a final order in August 2015.
■ Another enforcement case an- nounced in October 2018 brought even larger proposed penalties against a pet food manufacturer in New Jersey, a total of $152,829, for similar violations, along with other violations related to fall protection, respiratory protection, and powered indus- trial trucks. OSHA asserted that the manu- facturer failed to develop, document, and utilize procedures for controlling hazard- ous energy when employees were engaged in servicing or maintenance on blend mix- ing machinery and the associated electric and pneumatic equipment.
■ An enforcement case announced Sept. 27 against a Wisconsin company mainly concerned machine guarding vio- lations and fall hazards, but OSHA also cited the employer for not developing lockout/tagout procedures as required, not de-energizing a machine prior to an employee’s attempt to clear a jam, and not implementing the necessary energy control measures—machine isolation, applying a LOTO device, dissipating residual energy, and verifying machine isolation—to pro- tect the worker. Penalties proposed in this case totaled $221,726.
Jerry Laws is the editor of Occupational Health & Safety.
REFERENCES
1. https://www.osha.gov/dts/osta/lototraining/ tutorial/tu-over vw.html
2. https://www.cdc.gov/nora/councils/manuf/ loto/guide.html
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