How far do we need to go with LOTOTO procedures?
Please help me understand how far do we need to go with LOTOTO procedures. We have a comprehensive catalog of equipment-specific procedures, so I am comfortable there.
Here is where I need help -
Recently, a contractor had to shut off natural gas at the main to do pipe work inside the building. Do I need a LOTOTO procedure for shutting off the main valve? (This does get locked out, but is a written procedure needed?)
Another example. There is a section of liquid waste piping that needs to be replaced (nearly non-hazardous - mostly water). It has ball valves on either side of the section to be replaced. Does this need a written procedure?
I will be compliant and will provide valuable information to workers, but where does this end? Am I misunderstanding the regs and/or is there a section that helps clarify when a written procedure is needed/not needed in situations like these? If these do need written procedures, is there an efficient way of doing this for non-machine-specific LOTOTO? Such as a general procedure for many different tasks? Thanks.
Comments (3)
There is a note in 1910.147 for exceptions regarding when LOTO procedures do NOT need to be developed (see note below). As long as it falls within the scope of 1910.147(a)(1), and unless it meets ALL of the criteria mentioned below, then a written LOTO procedure needs to be developed to ensure all energy is being properly isolated.
"1910.147(c)(4)(i)
Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.
Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locked-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) 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."
Drew gave you a very great OSHA answer! I cannot top his OSHA answer.
Before I give you my answer from 50 years in manufacturing let me just say this. In my experience EVERY single amputation and most significant injuries I ever had to manage (In HR - WC and OHS for most of that 50 years, rest in Operations-Mfg.) the ROOT Cause of the accident was for the most part failure to Lockout, with a few of the rest Lockout being a very significant factor! The closest I ever came to a fatality was where an electrician failed to lockout a sub-station and got zapped with 15,000 volts! He was in a university burn center for over a year and the comp cost was in the millions! Your scenario somehow reminds me of that! By the way I was the first one to the electrician a sight that still haunts me 42 years after the accident!
My answer is you have to do whatever it takes to protect your employees and the resources of your employer. It comes down to, "Can any employee be hurt by the unexpected release of energy?" If so, you must protect them! simple as that. NOT only legally but morally!
A contractor cannot will not affect your WC exposure in your example. However you are NOT out of the woods. A contractor's WC carrier could subrogate the WC Claim and could sue you for negligence which will cost you huge bucks in Circuit Court if they can. Believe me, insurance companies will do whatever it takes NOT to pay and pass off liability! If you do not believe me report a motor vehicle accident to you personal insurance company. The first words out of their mouth when you report the accident will be were your working and any other questions to deflect liability (subrogation).
So the simple answer is you do what you need to do for your job!