Control exposure to hazardous energy
LOTO procedures control all steps required to successfully isolate a system component or machine prior to and during maintenance or other work in which someone is potentially exposed to hazardous energy. Each procedure must identify all isolation points and required devices, locks and/or tags needed to render the system or machine to a zero-energy state. These procedures should identify the magnitude of energy at hand and provide a safe, systematic shutdown prior to isolation. Many types of locking and tagging devices are available to support securing hazardous energy isolation devices in the OFF or CLOSED positions. Development of each isolation procedure should include first identifying the isolation points and then identifying the associated LOTO device to render the isolation point inoperable.
In situations where a system or machine contains multiple isolation points and there may be a need for various employees or contractors to be protected by the total isolation, control of multiple lock keys must be defined in written procedures. As an example, this can be accomplished by use of a group lockbox in which the unique keys from the multiple locks are placed into the group lockbox and then locked inside the lockbox by placement of a personal lock by one or more people requiring the protection of the specific isolation. Each person requiring this specific protection of the isolation, controls access to the contents of the lockbox by placement of his or her own personal lock. This personal lock will remain in place until the specific work task is complete.
Once the maintenance or servicing of the equipment is completed, procedures must be followed to restore energy and put the equipment back into safe operation. Should this occur during a shift change, or if for some other reason the maintenance person who has the LOTO clearance is not available, written procedures must contain the proper steps, sequences and authorities to remove the LOTO isolation.
Exception from the requirement to have a specific “Energy Control Procedure” is detailed in OSHA’s 29 CFR 1910.147 (c) (4) (i) LOTO regulation. According to the regulation, documentation of the procedures for a specific machine or piece of equipment may be required when a series of criteria are met. It is important to follow all of the guidelines outlined in section 1910.147 (c) (4) (i) for minor servicing to take place without a specific energy control procedure.
It is not always possible to have a documented procedure for every circumstance because procedures may vary based on the specific task being performed. In these instances, a work permit system may be used by having a safety manager perform a hazard analysis prior to the task being performed. The task-specific safe work procedure can then be documented in the work permit.
Training is key
Putting a training program in place ensures all levels of plant personnel recognize and understand the plant LOTO program. All employees must understand the importance of rendering a hazardous energy source into a zero energy state when performing maintenance activities. Standardized use of LOTO devices, locks and tags will provide visual communication to all employees that a LOTO is in progress. The use of standardized boundary ropes and barriers will add greater emphasis to this visual communication. This will alert all other employees not directly involved with the work in progress to remain at a distance from the work site. Authorized personnel should be specifically trained within their respective discipline, such as mechanical or electrical, to fully understand the operational aspects of the system and isolation devices. This training should include techniques to verify that the system or machine is in a zero-energy state and provide techniques for continuous verification to ensure there isn’t an accumulation of energy during the work duration.
An effective LOTO program does more than just fulfill the letter of the law for 29 CFR 1910.147. It should be valued as an important investment in safety and in preventing downtime. LOTO devices should be kept in excellent condition and evaluated periodically to make sure they meet current standards. Procedures should be kept in a place where everyone approaching the hazardous energy power source readily sees and has access to them. Training should be provided on a regular basis so all employees have the information they need. Evaluate the program periodically to assess if any changes or additions should be made. If employers treat LOTO as a “way of life” in a plant, the program will be taken seriously and used effectively by those it was designed to protect.