Energy Control Program Components
Management must develop, document, and make sure employees use specific written LOTO procedures to control potentially hazardous energy.
LOTO Procedure Requirements
The employer doesn't need to develop and use a written LOTO procedure for servicing or maintenance on a particular machine or equipment, but only when all of the following eight elements exist:
- The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees;
- the machine or equipment has a single energy source which can be readily identified and isolated;
- the isolation and locking out of the energy source will completely deenergize and deactivate the machine or equipment;
- the machine or equipment is isolated from the energy source and locked out during servicing or maintenance;
- a single lockout device will achieve a lock-out condition;
- the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
- the servicing or maintenance does not create hazards for other employees; and
- the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.
LOTO Procedure Elements
Electricity is not the only hazard!
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If the employer can't meet the above exception criteria, written LOTO procedures must be developed and used. The procedures for equipment with one or more sources of energy must outline the scope, purpose, authorization, accountability, and techniques that the employer will use to control hazardous energy.
- Scope. The scope might be limited to a single or group of similar pieces of equipment or machinery.
- Purpose. The purpose of the procedures is to ensure the unexpected energization/startup or shutdown does not occur during servicing or maintenance activities.
- Authorization. The responsible manager authorizes the procedures and ensures specific rules/techniques are listed within the procedures.
- The procedures must state the means to be used to enforce compliance. Typically, this requirement is met by stating the procedure is mandatory and may result in disciplinary action if not followed.
At a minimum, the procedures must include the elements listed below.
- A specific statement of the intended use of the procedure.
- Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy.
- Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices, and a description of who has responsibility for them.
- Specific requirements for testing a machine or piece of equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.
Tagout System Requirements
This is very important to remember: if an energy isolating device is not capable of being locked out, the employer's energy control program must use a tagout system.
Lockout System Requirements
If an energy isolating device is capable of being locked out, the employer must use a lockout system unless the employer can demonstrate that the tagout system will provide full employee protection. The employer may choose to use a tagout system as long as the requirements for additional training and periodic inspections are met.
Use of Tagout Devices
If the employer wants to use tagout devices when lockout devices are not capable of being used. Below is a list:
- The tags must be attached where the lockout devices would be located.
- The employer must demonstrate (prove) that the tagout system will provide protection at least as effective as locks and will assure full employee protection.
The employer must demonstrate the protection achieved using the tagout program is equivalent to the level of safety obtained by using a lockout program. That is not easy to do, so what must the employer do to prove equivalent protection? Here are some examples:
- removing and isolating a circuit element;
- blocking a controlling switch;
- opening an extra disconnecting device; and
- removing a valve handle to reduce the potential for any inadvertent energization while the tags are attached.
New or Modified Equipment
All new machines and equipment, or all machines and equipment that undergo major repair, renovations or modification, must be equipped with energy-isolating devices capable of accepting a lockout device.
After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine(s) or equipment must be designed to accept a lockout device.
That's about it for a discussion of the basic components of the ECP. Remember, make sure all three components have been developed and deployed. If OSHA comes inspecting, they will not cut you any slack when it comes to the LOTO program because if something goes wrong, a serious injury or fatality is likely to result. Okay... time for the quiz.
LOTO:Block the Shock!
Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the
module content, but only focuses on key concepts and ideas.
Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you
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