Page 30 - OHS, November/December 2021
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What are key components to set up proper energy control procedures? Below are just a few components you might want to consider:
■ Identify the energy types employed within a piece of equipment. Is it electrical energy only? Is the equipment piece in question operating with a large press brake with a stored energy component with gravity?
■ Identify how to isolate the energies that are external to the equipment.
■ Identify what stored energy remains after shutdown and how to release that stored energy.
■ Identify the way in which energy is controlled. Are these controls compliant and effective?
■ Evaluate current procedures and ask yourself: If these steps are followed, would I be safe putting my hand in potentially hazardous areas, or taking off guarding?
■ Ensure there is clear communication of proper LOTO procedures for each piece of equipment.
Opt for a visual LOTO procedure documentation that incorporates pictures. This is an effective tool to eliminate guesswork and increase
Helpful Reminders:
The Do’s and Don’ts
It all starts with shared ownership. Documenting and making standards easily accessible to employees is a starting point, not the endgame. A true commitment to safety and compliance will require training, reinforcement of protocols and open channels of communication.
Approach equipment with fresh eyes.
Even if a piece of equipment has been at your facility for decades, when it comes to safety, it needs to be looked at as if it had just been added to your line.
Ask questions. What energy sources does the equipment require? How does it operate? What does it do? What is the required maintenance and is there a plan in place for it? Where is the power shut
offff ? Are training manuals and OEM materials easily accessible?
Craftft easy to understand procedures. When documenting LOTO safety procedures, it is important to keep in mind the levels of experience and seniority of the employees coming in contact with a piece of equipment. The content needs to be easily digestible and always within reach. Remember that these materials need to answer key questions like how to recognize when a piece of equipment is at a zero-energy state and how to isolate a specific type of energy.
Label control points. A clear labeling system will be easily identifiable by your employees, and of course, it will need to correlate to documented procedures. Approach this from the perspective of a brand-new tech working on a piece of equipment. The importance of looking at safety measures with fresh eyes cannot be overstated.
Don’t stop with simple digital training content. While computer-based training programs, videos and other digital assets are powerful tools; best-in-class safety programs rely on robust content, assessments and field applications. Reinforcement is key to success.
QR code technology is your friend.
Labeling software has improved how control of hazardous energy in a facility is documented, labeled and audited. QR codes ensure that labels placed at each energy isolation point (EIP) are unique, this helps eliminate mistakes during maintenance and servicing. Scanning QR codes with mobile devices and tablets provides employees easy access to view, complete and audit LOTO procedures.
Standardization and visibility across multiple sites can be attained with the right technology. Safety procedures at the asset level are key to keep employees safe and protect equipment. However, a comprehensive view of a facility or multiple facilities can also be attained by employing asset management and visualization software. Asset management software can provide visibility into multiple locations via desktop/laptop with dashboards showing activities, dates, renewals, anniversaries and training for multiple-energy source equipment. These safety activities can be tied to existing computerized maintenance management systems (CMMS).
equipment in every industry continues to move toward automation, it is critical that assessments of new risks and safety procedures be performed. Furthermore, as equipment evolves so do the requirements to energize these assets, which in turn means LOTO procedures must be revised.
OSHA Looks to Plan
a Revised Standard
Speaking of revisions, OSHA concedes it is not keeping up with LOTO technological advancements. The agency has stated “computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with OSHA’s existing lockout/ tagout standard. The use of these computer- based controls has become more prevalent as equipment manufactures modernize their designs.”
OSHA’s 1989 LOTO standard has not kept pace with the national consensus standard ANSI/ASSP Z244.1, which is updated every five years to keep it relevant as technology and the nature of work changes. In the most recent regulatory agenda, OSHA proposed to update the old standard, which is over 30 years old, in January 2022.
Be Proactive
The world of LOTO is changing. Traditional control measures such as physical locks and tags are being challenged by computer-based controls as the workplace environment becomes more automated and digital. Most industrial environments rely on multiple energy types ranging from electrical, thermal and gas to radiation, vacuum, explosive and propellants; each source calls for a tailored safety approach. Knowing that a revised OSHA standard is in the works, our advice is: be proactive. Use internal experts from different departments or a “fresh pair of eyes” from a third-party service to assess if gaps exist between your written procedures and program and your sources of energy, control procedures, labeling, data collection and training. Remember that there are tools and software available to help you update and build a best-in- class LOTO program to protect your people and equipment.
Derek Hale is an electrical safety instructor and lead field analyst with SEAM Group.
Don’t forget about automation. As 30 Occupational Health & Safety | NOVEMBER/DECEMBER 2021

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