Our process equipment has so much inter-relationship between systems, and a lot of the service work we do is for unique situations. Are we supposed to have just one lockout procedure that covers everything?
Your lockout procedures would need to be specific to the job rather than to the machine itself if that’s what’s necessary to address the hazards. For example, if it would be absolutely safe for one part of process equipment to still have power while employees are doing repairs to another part of the equipment, you would only need to lock out the part of the equipment where the employees are working. You wouldn’t have to completely lock out the entire process if locking out part of it completely protects everyone. The extent of your lockout has to match the hazards, but you should be very careful about considering the potential for hazards to develop when you decide to only lock out part of the equipment.
Do authorized employees have to be trained to do all of the machine-specific procedures for all the machines in a facility, or can they just be trained on the procedures they do for the job?
OSHA’s lockout/tagout standard includes no requirement for authorized employees to know how to perform all of the facility’s machine-specific lock out/tag out procedures.
The training program under this standard will need to cover at least four areas: The employer's energy control program, the elements of the energy control procedures which are relevant to the employee's duties, the restrictions of the program applicable to each employee, and the requirements of the standard. The details will necessarily vary from workplace to workplace, and even from employee to employee within a single workplace, depending upon the complexity of the equipment and the procedure, as well as the employee's duties and their responsibilities under the energy control program.
We do all our repairs on first shift. Do we have to have second and third shift employees lock out the machine on their shifts even if they aren’t working on the machine?
If no one else will be working on the machine during a second or third shift, you can leave it locked out by the first shift employee until the first shift employee finishes the repairs.
If a first shift employee leaves and a second shift employee will continue working on it, then you have to transfer the lockout to the second shift employee. Usually the second shift worker will apply his lock as the first shift worker removes his.
If a second shift worker is leaving, and there isn’t a third shift, but the repairs are going to be finished by someone on the first shift, you don’t want to leave the second shift employee’s lock on the machine. In this case, OSHA says the second shift worker can replace the lock with a tag when he leaves. The machine will be tagged out when the first shift employee starts work. He can then replace the tag with his lock.
Are contractors supposed to use their own lockout procedures?
The rule says that you and the contractor have to inform one another of your respective lock out tag out procedures. Both of you have responsibilities for protecting your employees so you want to make sure everyone has enough information about the repair job to keep everyone safe. You probably know the most about how the equipment operates, but the contractor may know more about what’s going to be done during the repairs. Make sure you both have identified all the sources of hazardous energy and the contractor uses lockout procedures that control them all.
Aside from making sure the right procedures are followed, you (the host employer) have to make sure your employees comply with any restrictions from the contractor’s procedures. For example, your employees should be able to recognize the contractor’s lockout equipment and know to stay clear of the area where the work is being done.
Is it required to use plug covers to lock out power cord equipment?
The standard doesn’t apply to electrically powered machines that are completely disconnected by unplugging the cord – if the cord is under the exclusive control of the person doing the repairs. If this is the case, then no, you don’t need to lock a plug cover onto the plug.
If the machine has other energy supplies, or if the person doing the repairs won’t have exclusive control of the plug, then the standard would apply. You could use a plug cover to lock out the machine.
Do we have to lock out our forklifts when we do repairs?
Yes. OSHA’s compliance directive clarifies that the rules apply to vehicles such as forklifts, cars, trucks, and other vehicles.
Whether they’re powered by gas, propane, or electricity, vehicles have several types of hazardous energy that you need to disconnect and lock out during repairs. For example, batteries can cause electrical shocks and arcs, fuel systems can cause chemical exposures and fires, and mechanical energy from moving parts can cause crushing injuries.
If you want guidance on how to lock out vehicles, there’s a whole section on vehicle lockout in OSHA’s compliance directive. In some cases, the person doing the repairs is completely protected by removing the ignition key – if he’s the only person who has the key. Depending on the work being done, you might have to take other steps such as disconnecting the battery or inserting blocks to keep parts in place. OSHA says you should follow the vehicle manufacturer’s recommendations for how to do service and maintenance work.
We have large ovens. Do we have to account for the heat in the lockout procedure?
Yes, OSHA lists examples of energy sources in the rule’s definitions. They include: electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other types of energy.
Your procedures could treat the heat as stored energy and include a step for allowing the ovens to cool to a safe temperature before employees work on them.
We have process equipment. Does using bolted blinds and blank flanges count as lockout?
Blinds and blank flanges control hazardous energy in piping. The blinds and flanges are bolted in place, and this doesn’t involve an actual lock.
According to OSHA guidance, this method is just as difficult to defeat or bypass as is a lock. So, if you use bolted blank flanges and bolted slip blinds, it’s equivalent to using lockout.
If you do use this method, be sure to identify the persons who applied the controls. You can attach a tag to meet this requirement.