OSHA Standard 1910.147 is one of the most significant standards to impact work in the electrical business. While we generally fall into the guidelines of 1910.269 or 1926 Subpart V, depending on the work we are doing, it is safe to say that 1910.147 provides the road map for what we need to do to protect our workers when dealing with hazardous energy.
According to OSHA documents, compliance with lockout/tagout (LOTO) standards prevents an estimated 120 fatalities, 50,000 injuries and an average of 24 lost work days per worker each year. This has a tremendous impact on the injured employee and the company through costs, lost production time, hiring and training replacement workers, etc. While the financial impact should not be seen as the most important part, it does need to be considered in the scheme of things.
Crafting the right program
So, how do we craft a program that protects employees and enables us to complete work operations in a timely manner? OSHA gives us the flexibility to tailor our LOTO program to best fit our needs. Some will use strict lockout procedures or a tagout program that adheres to OSHA’s directive to add a “tags plus” aspect to the procedure, which includes at least one energy-isolating device with a tag affixed to it and at least one additional safety measure that, along with the energy-isolating device and tag required, will provide the equivalent safety available from using the lock.
What do you need to do?
- Develop an energy control program for LOTO. This program, once written, needs to be implemented and enforced throughout the course of work. Document these milestones for future review and confirmation.
- Use lockout devices for equipment that can be locked. You can use tagout devices in lieu of locks only if the tagout program provides the equivalent protection of a lock. This is where the “tags plus” initiative comes in.
- Ensure that when equipment is new or undergoes an overhaul, it is capable of accepting a lock.
- Ensure that each device used identifies the individual users (employees must sign onto the tag, either physically or electronically if electronic tagging is being used).
- Ensure that the person affixing the lock/tag is the only person who is authorized to remove it. In cases where work may overlap shifts, there needs to be a formal program identifying the steps needed to transfer the lock/tag.
- Review and update your procedure as necessary—no less than annually.
- Provide effective training to all employees who may be exposed to hazardous energy during their work.
The training must cover at least the following: 1) A thorough review of the energy control program; 2) The elements of the energy control procedure that are relevant to the employees’ duties; and 3) The various requirements outlined in the OSHA standards governing the work.
When using an outside contractor to complete work that involves LOTO operations where they are not following your program, document that a formal review of their program is done to ensure it meets the requirements set forth in the standards pertaining to the LOTO work. If following your program, document that you have trained the contractor in the requirements outlined.
While all of this may sound simple, the fact remains that we still see many injuries and fatalities from the failure to follow proper LOTO procedures. All too often, it’s “I was in a hurry to complete the job and I’ve done this a thousand times,” or “I thought everyone was off the line so we re-energized,” and the excuses go on and on. The simple fact is that you must follow the LOTO procedures for the specific job without deviation, because electricity kills!