Page 29 - OHS, November/December 2021

Lockout/tagout (LOTO) is a key safety program when working with any power source including electricity, hydraulic pressure, pneumatic pressure, water pressure, thermal energy and even pyrophoric chemicals that combust upon contact with the air.
Enterprise growth can also become the root of many challenges, particularly if safety programs are not properly scaled. Growth outpacing safety programs is one of the main reasons the 1910.147 control of hazardous energy (lockout/tagout) is on the top 10 list of OSHA’s most cited standards year after year.
LOTO Enforcement ■ Not paying attention to equipment stored energy. This is a
In the most recent year reported, fiscal year 2020, OSHA assessed a proposed $7.5 million dollars in penalties for violating the LOTO standard, making it the sixth most frequently cited agency standard. Food manufacturing, fabricated metal products, plastics and rubber products, wood products and primary metal manufacturing are the most heavily penalized industries.
More recently, in September 2021, OSHA proposed $1.67 million in fines for an Ohio aluminum parts manufacturer following an investigation into the death of a 43-year-old worker struck by a machine’s barrier door in March 2021. OSHA alleges the company allowed employees to bypass guarding mechanisms
common oversight identified during our gap analyses. If the only isolation valve for a piece of process equipment running 150 psi is in the ceiling, there is a high likelihood of stored pneumatic energy waiting to be released.
Effective Energy Control Procedures
OSHA estimates that LOTO standards compliance prevents 120 fatalities and 50,000 injuries each year. These numbers clearly illustrate the tangible effect proper LOTO procedures can have on employee safety, regulatory fines violations avoidance and uptime.
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NOVEMBER/DECEMBER 2021 | Occupational Health & Safety 29
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ned to protect them from the barrier door closing on them,
and that a malfunction in the door’s optic control existed prior to the deadly incident. The worker was loading a part into the machine when the barrier door closed, fatally injuring him.
“A worker lost his life because the company put the value of production speed before the safety of their employees. OSHA will continue to hold bad actors accountable and emphasize the importance of complying with safety and health requirements that can save lives,” said acting OSHA chief Jim Frederick in a press release found on OSHA’s online newsroom.
Common LOTO Procedures Oversights
LOTO gap assessments are conducted to ensure the procedures in place can indeed protect employees from injury and equipment from damage. Whether the assessment is conducted in-house, or outsourced to a third party, some of the most commonly found issues include:
■ Incomplete documentation of required training.
■ Failure to update procedures that reflect changes in operations and equipment. Example: Was a production line relocated to make way for a new process? Were procedures and training materials updated to reflect this change?
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