Authored by Edwin G Foulke, Jr. at Fisher Phillips
February 6th, 2018
This blog is an excerpt from our book Workplace Safety and Health Compliance Manual by Edwin G Foulke, Jr. at Fisher Phillips. For more information, go to the Products tab above and click on "Federal" to subscribe.
ENERGY CONTROL PROGRAM
FOR COMPLIANCE WITH OSHA 29 CFR SECTION 1910.147
This policy is intended to comply with the requirements for lock-out and/or tag out of energy sources to prevent personal injury under OSHA’s lockout/tag out standard. It shall apply to all employees and contractors of: (Company Name).
The company has adopted this program in order to implement the OSHA standard regulating the control of hazardous energy (lockout/tag out), 29 C.F.R. §1910.147. That OSHA standard, in §1910.147(c)(1), requires that each employer shall establish:
“[A] program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source, and rendered inoperative.”
Section 1910.147(c)(4) of that standard provides as follows:
“(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.
(ii) the procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following:
There is an exception to the foregoing. It provides that:
“The employer need not document the required procedure for a particular machine or equipment when all of the following elements exist:
The OSHA lockout/tag out standard 29 CFR Section 1910.147 can be found on the OSHA website at www.osha.gov. It covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy could cause injury to employees. It establishes minimum performance requirements for the control of such hazardous energy. The standard does not, however, cover the following:
The OSHA lockout/tag out standard applies to the control of energy during servicing and/or maintenance of machines and equipment, but it does not apply to:
IV. RELATED OSHA STANDARDS
A number of other OSHA standards contain various lockout/tag out requirements, which must also be observed when they apply. Those standards in part cover:
Powered Industrial Trucks
29 C.F.R. §1910.178(q)
Overhead and Gantry Cranes
29 C.F.R. § 1910.179(g)(5)
29 C.F.R. §1910.179(l)(2)
29 C.F.R. §1910.180(f)(2)
29 C.F.R. §1910.213(a)(10)
29 C.F.R. §1910.213(b)(5)
Mechanical Power Presses
29 C.F.R. §1910.271(b)(8)
29 C.F.R. §1910.217(d)(9)
29 C.F.R. §1910.218(a)(3)
29 C.F.R. §1910.218(d)(2)
29 C.F.R. §1910.218(e)(1)
29 C.F.R. §1910.218(f)(1)
29 C.F.R. §1910.218(f)(2)
29 C.F.R. §1910.218(h)(2)
29 C.F.R. §1910.218(i)(1)
29 C.F.R. §1910.218(j)(1)
Welding, Cutting and Brazing
29 C.F.R. §1910.252(c)(1)
29 C.F.R. §1910.252(c)(2)
Pulp, Paper and Paperboard Mills
29 C.F.R. §1910.261(b)(4)
29 C.F.R. §1910.261(f)(6)
29 C.F.R. §1910.261(g)(15)
29 C.F.R. §1910.261(g)(21)
29 C.F.R. §1910.261(j)(4)
29 C.F.R. §1910.261(j)(5)
29 C.F.R. §1910.261(k)(2)
29 C.F.R. §1910.262(c)(1)
29 C.F.R. §1910.262(n)(2)
29 C.F.R. §1910.262(p)(1)
29 C.F.R. §1910.262(q)(2)
29 C.F.R. §1910.263(k)(12)
29 C.F.R. §1910.263(l)(3)
29 C.F.R. §1910.263(l)(8)
29 C.F.R. §1910.265(c)(12)
29 C.F.R. §1910.265(c)(13)
29 C.F.R. §1910.265(c)(26)
Grain Handling Facilities
29 C.F.R. §1910.272(e)(1)
29 C.F.R. §1910.272(g)(1)
29 C.F.R. §1910.272(l)(4)
The lockout/tag out requirements of those standards must be followed when they are applicable and they must also be supplemented by the procedural and training requirements of the OSHA lockout/tag out standard, 29 C.F.R. §1910.147.
Affected Employee - means an employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tag out, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed. (The same person can simultaneously be both an affected and an authorized employee. See the definition of “Authorized Employee.”) Employees who exclusively perform functions related to normal production operations and who perform servicing and/or maintenance under the protection of normal machine safeguarding are treated as “affected” rather than “authorized” employees. See the discussion above under “Application”.
Authorized Employee - means a person who locks out or tags out machines or equipment in order to perform the servicing or maintenance on that machine or equipment. (An authorized employee and an affected employee may be the same person when the affected employee’s duties also include performing maintenance or service on a machine or equipment which must first be locked out or tagged out.)
Capable of Being Locked Out - means an energy-isolating device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed, or it has a locking mechanism built into it. Other energy-isolating devices are capable of being locked out, if lockout can be achieved without the need to dismantle, rebuild, or replace the energy-isolating device or permanently alter its energy-control capability.
Energized - means connected to an energy source or containing residual or stored energy.
Energy Source - means any source of electrical, mechanical, hydraulic, pneumatic, chemical, nuclear, thermal or other energy.
Hot Tap - means a procedure used in the repair, maintenance and services activities which involves welding on a piece of equipment (pipelines, vessels or tanks) under pressure, in order to install connections or appurtenances. It is commonly used to replace or add sections of pipeline without the interruption of service for air, gas, water, steam and petrochemical distribution systems.
Lockout - means the placement of a lockout device on an energy-isolating device, in accordance with an established procedure, ensuring that the energy-isolating device and the equipment being controlled cannot be operated until the lockout device is removed.
Lock-out Device - means a device that utilizes a positive means such as a lock and key (or a combination-type lock) to hold an energy-isolating device in a safe position and prevents the energizing of the machine or equipment in order to protect personnel from injury. Included are blank flanges and bolted slip blinds.
Lock-Out/Tag-Out - means the placement of a lock/tag on an energy-isolating device in accordance with established procedure to assure that the energy-isolating device will not be operated until removal of the lock/tag.
Maintenance - (See “Servicing and/or Maintenance”)
Normal Production Operations - means the utilization of a machine or equipment to perform its intended production function.
Other Employee - means an employee who does not work on the machinery or equipment that is locked out or tagged out, but whose work operations are or may be in the area where there are servicing or maintenance operations subject to the lockout/tag out requirements and procedures.
Servicing and/or Maintenance - means workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may exposed to the unexpected energization or startup of the equipment or release of hazardous energy.
Setting Up - means any work performed to prepare a machine or equipment to perform its normal production operation.
Tag Out - means the placement of a tag out device on an energy-isolating device, in accordance with an established procedure, to indicate that the energy-isolating device and the equipment being controlled may not be operated until the tag out device is removed.
Tag Out Device - means a prominent warning device, such as a tag and a means of attachment, which can be securely fastened to an energy-isolating device in accordance with an established procedure, to indicate that the energy-isolating device and the equipment being controlled may not be operated until the tag out device is removed.
VI. EMPLOYEE RESPONSIBILITIES
VII. DISCIPLINE FOR NONCOMPLIANCE
Disciplinary actions will be taken against any employee who fails to observe any rule listed above under “Employee Responsibilities,” who does servicing or maintenance work on, or comes within physical contact of, any machinery or equipment that is required to be locked or tagged out at a time when it has not been properly locked or tagged out, or who fails to comply with any restriction, limitation or obligation imposed by our lockout/tag out program and procedures or by OSHA lockout/tag out requirements.
Any manager, foreman, supervisor or official of management, as soon as he/she becomes aware of any such failure, shall ensure that the following action is taken:
VIII. LOCKS AND TAGS
Each authorized employee who works with machinery or equipment subject to the company’s lockout procedures will be issued a padlock with one key.
The locks issued to employees have been determined to be capable of withstanding the environment to which they are exposed for the maximum period of time that exposure is expected, and substantial enough to prevent removal when in place by any means (other than the regular key) without the use of excessive force or unusual techniques (such as with the use of bolt cutters or other metal-cutting tools).
Any person who knows of any lock that does not satisfy the above must immediately report that fact to his supervisor. That supervisor shall take immediate steps to ensure that the lock in question meets the above or that a suitable replacement lock is provided.
Under company policy, lockout is the preferred method to assure against injury. The use of tags in the deenergization process and in preventing unauthorized start-up of machines and equipment is therefore limited to:
The tags to be used in those situations will be provided by the company. Each tag must indicate the identity of the employee who applies it (examples of such tags are attached). The tags to be used have been determined by the company to be capable of withstanding the environment to which they are exposed for the maximum period of time that exposure is expected. They have been constructed and printed so that exposure to weather conditions, wet or damp locations or corrosive environments (such as areas where acid and alkali chemicals are handled and stored) will not cause the tag to deteriorate or the message on the tag to become illegible.
Tags that are reusable, non-locking, or easily detached (such as string, cord, or adhesive) are not permitted.
All tags to be used have been standardized by color, shape, size, print and format. They are non-reusable, self-locking, attachable by hand, non-releasable with a minimum unlocking strength of no less than 50 pounds, and have the general design and basic characteristics of being at least equivalent to a one-piece, all-environment-tolerant nylon cable tie.
Each tag contains a warning against hazardous conditions if the machine or equipment should be energized. They contain words such as:
DO NOT START
DO NOT OPEN
DO NOT CLOSE
DO NOT ENERGIZE
DO NOT OPERATE
Any employee or contractor who knows of the use of any tag that does not satisfy the above must immediately report that fact to his supervisor. That supervisor shall take immediate steps to ensure that the tag in question satisfies the above or that a suitable replacement tag is provided.
IX. LOCKOUT PROCEDURE
Lockout shall be performed only by the authorized employees who are performing the servicing or maintenance. No one will be permitted to perform lockout who is not thoroughly familiar with the machinery/equipment involved. That familiarity must include:
(a) Knowledge of the type and magnitude of the energy;
(b) The hazards of the energy to be controlled; and
(c) The means and methods to control the energy.
Lockout shall be performed as follows:
1. Review lockout/tag out plans and procedures.
2. Make a survey to locate and identify all isolating devices in order to be certain which switch(es), valve(s) or other energy-isolating devices apply to the equipment to be locked out. Bear in mind that more than one energy source (electrical, mechanical, or others) may be involved.
3. Notify all affected employees of the lockout requirement and the reasons for its use. The authorized employee must know the type and magnitude of energy that the machine or equipment utilizes, and the means and methods to control that energy, and must understand the hazards thereof.
4. Shut down operating equipment by the normal procedure (depress stop button, open toggle switch, etc.)
5. Operate the switch, valve or other energy-isolating device so that the energy sources (electrical, mechanical, hydraulic, etc.) are disconnected or isolated from the equipment. Stored energy, such as that in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems (air, gas steam or water pressure), etc., must also be dissipated or restrained by methods such as:
6. Lock out all of the energy isolating devices with an assigned individual lock. Affixed the lock in a manner that will isolate the machine or equipment from the energy source(s) – hold the energy-isolating devices in a “safe” or “off” position. Keep the key in your possession.
7. After the lock is in place, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe.
8. Operate push button or other normal operating controls to make certain the equipment will not operate. CAUTION: You must first assure that no personnel are exposed. If there is a possibility of reaccumulation of stored energy to a hazardous level, verification of isolation shall be continued until the servicing of maintenance is completed, or until the possibility of such accumulation no longer exists.
9. Return operating controls to neutral position after test.
10. The equipment is now locked out.
B. Restoring Equipment to Service
1. When job is completed and equipment is ready for testing or normal service, check the equipment area to see that no one is exposed.
2. Inspect the work area to ensure that nonessential items have been removed and to ensure that the machine or equipment components are operationally intact.
3. When equipment is all clear, all locks shall be removed and affected employees shall be notified that the locks have been removed.
4. The energy-isolating devices may now be operated to restore energy to the equipment.
NOTE: The lock shall only be removed by the same employee who put the lock on the energy isolating device. However, when the authorized employee who applied the lock is not available to remove it, it may be removed under the direction of his supervisor, but only if it is first:
Our lockout/tag out training program includes additional training and instruction on this process.
C. Special Considerations
1. Procedure Involving More Than One Person - (Group Lockout)
D. Temporary Removal of Locks
In those situations where the lock must be temporarily removed from the energy-isolating device and the machine or equipment energized to test or position the machine, equipment or component thereof, the following sequence of actions shall be followed:
1. Clear the machine or equipment of tools and materials in accordance with part “B” above: “Restoring Equipment to Service”;
2. Remove employees from the machine or equipment area;
3. Remove the lock;
4. Energize and proceed with testing or positioning;
5. Deenergize all systems and reapply energy control measures in the sequence set forth in part A, above, in order to continue the servicing and/or maintenance;
6. The steps taken to re-energize the equipment are the same as those set forth above in part B (Restoring Equipment to Service). All the requirements of those steps must be observed.
E. Shift Changes and Personnel Changes
If the lockout continues beyond the end of the shift of the employee who locked it out, it will remain in the locked out position until the same employee returns to the job. The only exception to this rule is that set forth in the NOTE: following part B above.
X. TAG-OUT PROCEDURE
In those instances where machinery or equipment is tagged out, rather than locked out, the lockout procedures listed above will be followed except that the tags described above will be used instead of locks. The following additional requirements will also be taken:
The company has a training program for all employees who work with machinery or equipment subject to lockout/tag out requirements, including those employees who do not work directly on that machinery or equipment but whose work operations are or may be in the area. An employee must successfully complete the training program before he/she will be permitted to work in the area of, or perform any servicing or maintenance upon, any machinery or equipment that is subject to OSHA lockout/tag out requirements.
The program is described briefly below:
XII. PERIODIC INSPECTION
The company supervisor with responsibility for maintenance of machinery and equipment, or a person (or persons) designated by the supervisor, will conduct periodic inspections at least once a year in order to verify the effectiveness of the employees’ knowledge of the energy control (lockout/tag out) procedures and observance of OSHA lockout/tag out requirements for the different pieces of equipment. Those inspections will include:
XIII. MACHINES/EQUIPMENT COVERED BY THIS PROGRAM
The supervisor responsible for the maintenance and servicing of each machine and item of equipment that is subject to the lockout/tag out requirements, or a person or persons designated by that supervisor, shall obtain or prepare a written procedure that will identify (by name, machine number, category or similar identifying criteria) the particular machine (or group of machines) and equipment (or items of equipment), and include:
XIV. LIST OF EMPLOYEES' NAMES
The supervisor responsible for the maintenance and servicing of each machine and item of equipment that is subject to the lockout/tag out requirements, or a person or persons designated by that supervisor, will maintain a current list containing the names of:
The list of employees and the particular lockout/tag out procedures for the machines/equipment covered by this program do not have to be separate documents.
XV. OUTSIDE CONTRACTORS
Whenever outside contractors or outside servicing personnel are to be engaged by the company to perform activities covered by the scope and application of the OSHA lockout/tag out standard (29 C.F.R. §1910.134), the designated company official will inform the contractor(s) of the relevant lockout/tag out procedure, and shall obtain from them the lockout/tag out procedure they will use on our premises.
All affected company employees will be provided with sufficient information and instruction regarding the outside contractors’ (or outside service personnel’s) energy control (lockout/tag out) program to enable the employees to understand and comply with its restrictions and prohibitions.
Each matter covered in this lockout/tag out program is interrelated. Consequently, this program is enforced by each employee’s continued compliance with all procedures, rules, regulations and orders applicable to his/her own actions and conduct. Each employee is expected to take appropriate action when noncompliance occurs.