Machine Specific LOTO instructions
Do the machine specific steps of LOTO need to include steps found in the LOTO procedure (ex. notify affected employees, shutdown, isolate, apply, etc.) or is the energy sources, locations methods, checks and devices used appropriate?
I am looking for any gray area between operator risks and maintenance risks.
Thank you!
Comments (7)
I have always included the general steps (e.g., notify affected employees, shutdown, etc.) at the top of each LOTO procedure document, then put the identication/location of each isolation point (including a picture), magnitute of the energy, LOTO device needed and where to apply it, and how to verify the energy is isolated in the middle of the document.
ANSI Z244.1-2016 has some good sample LOTO procedures and guidance to follow, if you have that standard available.
Everyone above is correct!
In my opinion for a highly effective Lockout Program you must train and apply "The Application of Control" the 7 or 8 Steps of LO. Application of Control is mentioned and required in 1910.147(c)(7)(d). The 8 Steps are (d)(1) - (e), with several sub-paragraphs.
Again, in my opinion the best machine specific LO procedures include the 8 steps or elements of the Application for Control.
To be specific, you are the correct a couple steps are the same no matter the machine, like notification, isolation, and so forth. SO just include them in your template for your specific procedures so you just have to complete the machine specific things, like where to place the locks. Do not make it hard. Another option is to make the universal or macro steps an important part of your Authorized Training and hope you employees remember. I just do not think that is the best.
Most of my experience is in machining and assembly operations. In my jobs of HR, OHS, and Ops I do not (in 50 years) ever recall a mechanic or setup employee telling everyone that machine # XXX is going to be locked out. Usually "everyone" knows machine #XXX is down or being setup and this step is not done. Will OSHA right you up if they see it not don? No guarantee but I think not unless somehow someone got hurt not doing so, which on individual machine unlikely. AS far as the last step telling everyone the machine is ready to go, especially on critical machines in OPS you can bet I was keenly aware on when I could have the machine back and running. I wish I had a $1 for every time I had a Maintenance Supervisor call me a nasty name because I was all over him for my machine!
Be specific, explicit. Take pictures of all forms of energy sources with arrows, circles so it is clear where they are located. If the LOTO point does not match the picture fix it.