Page 39 - Occupational Health & Safety, March 2019

LOCKOUT/TAGOUT
Lockout/Tagout (LOTO): Electrical Safety Simplified
LOTO is an integral part of the electrical safety requirements contained in the NFPA 70E Standard for Electrical Safety in the Workplace.
BY ROBERT J. ST. PIERRE
www.ohsonline.com
MARCH 2019 | Occupational Health & Safety 33
OSHA Mandate: The Law
The Occupational Safety and Health Administration, OSHA, has some minimum requirements that are invoked whenever employees are going to perform installation, maintenance, or repair on equipment. There are three major sections that apply when this occurs:
■ CFR 1910.147, which applies for General In- dustry applications
■ CFR 1926.147, applicable to Construction
■ CFR 1910.133 Subpart S, which directly in- volves electrical hazards
NFPA 70E: Industry Best Practice
The NFPA 70E standard is produced by the National Fire Protection Association, they are one of the major players when it comes to producing standards that are used for various applications in the modern world. One of their standards that is used worldwide is NFPA 70, or the National Electrical Code, more commonly referred to as the NEC. There is also NFPA 70B, which applies to maintenance standards for electrical equip- ment that are also interwoven into the NFPA 70E standard. The final piece is NFPA 70E, which is the commonly used standard in the United States for elec- trical safety, as well as being applied worldwide within certain industries. These include oil and gas produc- tion as well as paper production.
OSHA vs. 70E: Why the Two?
Although the OSHA regulations are the minimum standards for encompassing, among other things, lockout/tagout (LOTO) for electrical safety, there are several reasons why the 70E is commonly used. His- torically, the NFPA appointed a new electrical safety committee in 1976 to help OSHA implement an elec- trical safety standard that could be quickly used as an extension of the OSH act. Some of the requirements involved having the public involved in the adoption and modifications in the form of notice, comments, and hearings.
The standard then in common use was the NEC, and it was thought that reworking this document in this manner would entail excessive effort and might result in a document that would differ excessively from what the NEC would otherwise contain. Ad- ditionally, the NEC in its current form is used basi- cally for electrical installations and is not directly ap- plicable to personnel safety. The NFPA realized that
a need existed for a safety standard that OSHA could promulgate and still coordinate with the NEC.
This concept and offer of cooperation was pro- posed to OSHA and in May 1975 OSHA responded in a positive manner, so the concept of an electrical safety standard was born.
Any person who may be exposed to the electrical energy should be party to the LOTO procedure.
NFPA 70E: LOTO Requirements
The terminology that is commonly used within the safety community for LOTO is an “electrically safe work condition.” This refers to an area that has been deemed “safe” from electrical hazards. Some common terms that are used for both OSHA and 70E purposes are the following:
Authorized person: Someone who is permitted due to knowledge of equipment or system to lock/tag the system in a safe and controlled manner, typically equipment operators.
Qualified person: Someone who is knowledgeable of the system enough to be able not only to lock/tag the system, but also troubleshoot, repair, or maintain the system again in a safe and controlled manner, typ- ically technicians, electricians, etc.
Affected person: Person who may be exposed to the hazards of energizing or de-energizing the equipment or system.
PPE: Personal protective equipment for electrical hazards: rubber insulating gloves for shock hazard and arc flash-rated clothing for arc flash hazards.
LOTO: Lockout/tagout, when an electrical system or equipment has been disabled to such an extent as to render the system safe from electrical hazards for interaction with personnel.
General LOTO requirements for the employer consist of the following:
1. Shall implement a LOTO program that will in- clude written procedures for their electrical systems.
2. Provide necessary equipment for LOTO pro- gram (locks, tags, diagrams, etc.).
3. Provide documented LOTO training to all workers exposed to the hazards.
4. Should audit the LOTO program as a whole to ensure compliance with the written program.
5. Also should audit individual personnel who im- plement the LOTO procedure to ensure compliance