Page 24 - OHS, March 2021
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Striving for the minimum requirements of compliance does not lead to achieving minimum risk.
might mean we’ve got to have more classroom training sessions.” This is true as it relates to electrical safety and the Control of Hazardous Energy. When training in your Electrical Safety Program, start by looking at the recurring top ten most cited OSHA violations related to the Control of Hazardous Energy. This standard is under OSHA regulation CFR 1910.147, which covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could harm personnel. In 2019, the second most cited violation under Control of Hazardous Energy was the Communication & Training regulation CFR 1910.147(c)(7). As Dankert pointed out, the CDC guidelines for operation have changed the way we can perform training. In addition, loss of revenue is a primary factor for maintaining the integrity of your Electrical Safety Program. The most important investment an employer can make is in their employee’s health and safety. This
should be the last area cut from the budget, not one of the first. Failure to perform proper mechanical or electrical Lockout/ Tagout (LOTO) can lead to electrocution, electrical shock, arc- flash and other hazards. In addition to huge penalties, these hazards often result in lost time wages, compensation claims, permanent disability and fatalities. From 2011 to 2015, the U.S. Department of Labor reported an average of 150 fatalities per year in the United States due to “exposure to electricity,” and more than 50,000 injuries for disregarding LOTO protocols. The Bureau of Labor Statistics also reported an average of 2,370 non- fatal electrical injuries a year due to electrical shock and electrical
burns in the last decade.
Lockout/Tagout Violations
Despite the potential for preventing an estimated 150 fatalities and 50,000 injuries each year, LOTO procedures consistently account for one of the most cited OSHA violations each year. In 2019, the LOTO Control of Hazardous Energy standard 29 CFR 1910.147 placed fourth in OSHA’s Top 10 List of most cited violations with 2,975 total violations—higher than the previous year. This standard outlines the minimum performance requirements for the control of hazardous energy during servicing and maintenance of machines and equipment.
Employers cited under this standard failed to establish an energy control procedure either partially or altogether, while others were cited for failing to provide adequate employee training, failing to conduct periodic evaluations of procedures and failing to use LOTO devices or equipment. Violations were
common among plastics manufacturers, machine shops and sawmills. Penalties for 2019 citations can cost as much as $13,260 per violation, and failure to act can lead to additional fifines up to $13,260 per violation per day past the deadline to fifix the issue.
At the National Safety Council Congress & Expo in 2019, Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs reported: “These are common violations that we’re finding—they’ve been in place for a lot of years. The answers are out there, and employers shouldn’t feel like these are very complex issues. If you don’t know the answers, we encourage you to contact OSHA.”
Since 2014, OSHA has issued employers more than 10,000 LOTO citations. In addition to the penalties paid for safety violations, preventable workplace incidents involving the release of stored energy cost companies millions in lost productivity, medical expenses and insurance costs. With the available resources today, these completely preventable accidents and their associated costs should be on the downturn, as opposed to 2019 when we saw an increase in violations over the previous years.
“I would like to remind people, as difficult as it is to be in compliance, that is the minimum that we must do to protect employees. OSHA doesn’t have a standard for every possible hazard that we might have in our facility or on our jobsite,” Dankert said. “So as difficult as it is to be compliant, we also need to understand the inherent hazards in our processes that OSHA doesn’t cover and seek those best practices to continue to protect our employees.”
Striving for the minimum requirements of compliance does not lead to achieving minimum risk or maximum productivity levels available today. Furthermore, human error plays a vital role in failing to comply with standards. Despite thorough training, documentation and experience, there will always exist that risky margin of a person just simply making a mistake, no matter how many times they have performed the task at hand.
For example, qualified maintenance personnel performing mechanical LOTO are tasked with isolating electrical energy. As part of the verification of de-energized condition, OSHA requires a person to operate the equipment controls, also known as a try/test, to ensure the equipment cannot be restarted. There are several significant risks associated with solely relying on the try/ test. These risks often include isolating wrong controls, accidental restart of the equipment, getting caught in the equipment or contact with live source of energy at the machine level.
Safety conscious and forward-thinking companies understood these risks early on and started to require electricians to perform absence of voltage testing for mechanical LOTO. With the advent of NFPA 70E and research on Arc Flash, employers began to realize through job hazard analysis that this task, while reducing the hazards of the energized condition of the equipment, greatly increased the exposure to electricity in performing the test itself. Additionally, the involvement of an electrician in a simple mechanical LOTO further hampered productivity.
A safety-by-design solution was found for this scenario in an externally mounted LED voltage presence indicator. This provides an alternative means to verify the voltage presence inside an electrical panel while safely unexposed from the outside in addition to the OSHA required try/test. Without a voltage indicator, a mechanic performing mechanical LOTO would be required to work in tandem with an electrician using a voltmeter
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