Guest post by James Pryor
We like to make parts. That is the nature of our business. When we think of workplace safety we generally think in terms of accidents related to the fabrication of machined parts such as hand and eye injuries.
However, the most frequently cited threat (Current OSHA data) safety violation for machine shops is the Control of Hazardous Energy (Lockout/ Tagout). – OSHA 10/09 -09/2010.

I prefer a padlock myself...

 Lockout / Tagout OSHA standard 29 CFR 1910.147 requires all employers to provide protection for employees performing maintenance and servicing on equipment or machines from the accidental start up or release of energy which could result in an employee being injured.

  • When was the last time you reviewed your control of hazardous energy procedures?
  • When was the last time you performed an audit to assure they are being followed?
  • Does someone review the requirements for control of hazardous energy whenever there is a change in your systems such as the introduction of new equipment?

 Training on these changes is a federal requirement.
The following review  questions are provided to help you assure that your control of hazardous energy covers all the bases.

  • Do you have a written company policy on the control of hazardous energy? Is the role of management clearly defined?
  • Have supervisors been trained in lockout/tagout procedures?
  • Have authorized employees been trained in lockout/tagout procedures?
  • Have affected employees been trained in lockout/tagout procedures?
  • Have other employees been trained in lockout/tagout procedures?
  • Are the approved locks and tags in place and in use?
  • Is there a written lockout / tagout procedure and have employees been trained?
  • Does this plan include warnings, testing and positioning of equipment and procedures for restoring machines and/ or equipment to normal production operations?
  • Does the plan include procedures for more than one person?
  • Does the plan include shift changes?
  • Does the plan include an annual audit of authorized employees?
  • Does the plan include procedures for multiple energy source equipment?
  • Does the plan include minor tool changes and adjustments?
  • Does the plan include emergency lock removal procedures.?
  • Does the plan include provisions for qualified employees?
  •  Does your company enforce the plan and document enforcement?
  • Does the plan allow for re-training?
  • Does the plan clearly define roles and responsibilities?

Control of hazardous energy is the most cited failure in our industry, we hope that these review questions will help you keep your workers safe and your program in compliance.

Many folks associate September 11 with the year 2001 and the horrific attacks to the World Trade Center and the Pentagon.  That is appropriate and respectful.

This should be a common sight in your shop.
This should be a common sight in your shop.

But professionally, I associate September 11 with 1990, the year that the US Dept. of Labor issued their OSHA instruction STD 1-7.3  Subject: 29 CFR 1910.147 the control of hazardous energy (Lockout/Tagout) – Inspection Procedures and Interpretive Guidance.  
Here are 7 questions you should answer to make sure you’re in compliance: 

  1. Do you have a written hazardous energy control program in your shop? When did you last revise it and review hazards?
  2. Do you have documented hazardous energy control procedures? Can you show me evidence of employee training?
  3. Does your program have a means of dealing with outside contractors?
  4. If an inspector asks an employee what is the procedure for removing another employee’s lock, what will they say?
  5. Does each employee have their own personal lock out device?
  6. Are the lockout points identified on every power driven machine in your shop
  7. Can you show me the actions that you took / follow up to your annual review and certification of your shop’s energy control program?

Lockout Tagout Hazardous Energy Control Violations continue to be a high violation in our industry by OSHA. This is 2009. So in the 19 years since 1990, you would think that our companies would have this lockout tagout stuff figured out by now, right?
Here’s a construction example of what can happen when there is a failure to properly lockout electrical energy.
Here is OSHA’s Booklet 3120 on Control of Hazardous Energy 
Photo courtesy of the Workplace Safety Store, who offers DVD VHS Lockout Training Refresher Program.