I mean...am I wrong?
By not following OSHA's minimum requirements, as well as applicable consensus standards (such as ANSI Z244.1), we are setting our employees up for failure. If we fail to train them properly and/or simply give them generic LOTO instructions (e.g., "Just turn it off and throw a padlock on it and you'll be fine!"), we are putting our employees' lives on the line. If all energy sources are not identified and communicated to authorized employees prior to performing the work, we are placing their lives in jeopardy.
OSHA requires you to develop machine-spefic energy control (LOTO) procedures for your workplace, including:
(1) specific procedural stepsfor shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;
(2) specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and
(3) specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.
In addition, each authorized employee must receive training in the recognition of applicable hazardous energy sources (e.g., electrical, pneumatic, gravity), the type and magnitude of the energy available in the workplace (e.g., 480 VAC, 120 PSI of compresed air, etc.), and the methods and means necessary for energy isolation and control (e.g., how to properly use a ball valve lockout device).
Comments (10)
Not sure I would broadcast that I "follow" this cat. I would tend to do the opposite of what he says to do. But who am I? He is the Billionaire (at least one paper) not me!
But your point is well taken and that is the way I train and teach it! There is a lot more to LO but this has to be included.
I had 18 year old gal, a month out of high school, lose three fingers on her right hand (and she was right handed) when the Machine Specific Procedures did not identify spring tension energy in a compressed feed collet. Our engineers, ops, and equipment procurement people missed that one! She had locked out the power and locked out the pneumatic controls per the established lockout procedures on the machine. she thought she had relieved all the energy. They knew their was no hydraulics and did not think the piston was dangerous with the power and air gone, but did not know about the spring tension that had to be neutralized too. We blew it! I always have felt terrible about that after 30 years!
Man this one has hit super close. Culture and Policy heading on a collision path of NOTHING GOOD!