Final Words: Comply, Comply, Comply

This series has focused on the Occupational Safety and Health Administration's "Control of Hazardous Energy" standard, 29 CFR 1910.147 -- also known as the lockout/tagout standard. It specifically addresses practices and procedures necessary to disable machinery or equipment and to prevent the release of potentially hazardous energy while maintenance and servicing activities are being performed. The standard applies to any source of mechanical, hydraulic, pneumatic, chemical, thermal or other energy.

In last month's installment, I offered the beginning steps of a procedural example for group lockout/tagout. This month, I conclude the lockout/tagout series with the remaining steps.

Note that all of the previous steps should have been documented by a master system of accountability and retained at the primary equipment control station for the duration of the job. The master system of accountability may manifest itself as a master tag, which is subsequently signed by all of the maintenance and servicing workers if they fully comprehend the details of the job and the energy-isolation devices actuated or put in place. This signing by the respective workers further verifies that energy-isolation training relative to this operation has been conducted.

After the system has been rendered safe, the authorized employees verify energy controls as described in B.3.b.(1) of the standard's appendix.

Specific work functions are controlled by work permits that are issued for each shift. Each day, each authorized employee assigned must sign in on the work permit at the time of arrival to the job and sign out at departure. Signature, date and time for sign-in and sign-out would be recorded and retained by the applicable crew supervisor who, upon completion of the permit requirements, would return the permit to the operations supervisor. Work permits could extend beyond a single shift and may subsequently be the responsibility of several supervisors.

Upon completion of the tasks required by the work permit, the authorized employees' names can be signed off the master tag by their supervisor once all employees have signed off the work permit. The work permit then is attached to the master tag. (Accountability of exposed workers is maintained.)

As the work is completed by the various crews, the work permits and the accountability of personnel are reconciled jointly by the primary authorized employee and the operations supervisor. During the progress of the work, inspection audits are conducted. Upon completion of all work, the equipment is returned to the operations personnel after the maintenance and servicing crews have removed their locks, tags and special isolating devices following the company procedure.

At this time, all authorized employees who were assigned to the tasks are again accounted for and verified to be clear from the equipment area. After completing the servicing or maintenance work, operations personnel remove the tags originally placed to identify energy isolation. Operations personnel then begin check-out, verification and testing of the equipment prior to it being returned to production service.

IF YOU VIOLATE

It is my hope that the last seven installments of "Safety Zone" have helped you understand OSHA's lockout/tagout standard and why it is important to comply. I am wrapping up this series with OSHA's classification of violations, as stated in its compliance directive:

  • A deficiency in the employer's energy-control program or procedure that could contribute to a potential exposure capable of producing serious physical harm or death shall be cited as a serious violation.

  • The failure to train "authorized," "affected" and "other" employees as required for their respective classifications normally should be cited as a serious violation.

  • Paperwork deficiencies in lockout/tagout programs where effective lockout/tagout work procedures are in place shall be cited as other-than-serious.

John Maronic, assistant OSHA area director in Des Plaines, Ill., notes that serious violations can cost a company upwards of $7,000 per violation for a first-time offense. And, if that violation is deemed willful, the fine soars up to as much as $70,000 per violation. If the violation is repeated once within three years, the fine doubles. A second repeat offense will cost five times that of the original fine.

Keep your employees safe and your company's money invested in its business. Comply, comply, comply!