Lockout/Tagout and Machine Guarding

Background:

  • This lockout / tagout (LOTO) program is intended for all departments at UWM. Departments may modify this program or develop their own written program to meet individual departmental needs.
  • The purpose of this program is to identify the procedures necessary to shut down and lock out or tag out machines and equipment where the unexpected energizing or start-up of the equipment or release of energy could cause injury.
  • Hazardous energy appears in the workplace in the form of electrical, mechanical, pneumatic, hydraulic and thermal energy and includes chemical, water, steam and gaseous energy systems. Lockout/Tagout procedures prevent the unexpected energization, start up or release of stored energy that could cause injury while working on equipment. OSHA estimates that nearly 2% of all deaths in the workplace would be affected by adherence to this rule .
  • The program is applicable whenever employees (students) install, repair, set up or service equipment or machinery, or if employees are required to remove or bypass a guard or safety device.
  • The program requires that employees receive training and requires that periodic inspections be conducted to maintain and enhance the program.

Responsibility for Compliance:

Departments are required to implement a LOTO program. A majority of the hazardous energy sources on campus are either the responsibility of Facility Services or Auxiliary Services (e.g., Sandburg and Union operations).

Academic departments need to implement a program and incorporate students where applicable.
  • Directors, chairs or their delegate are responsible for determining which activities involving the use of hazardous energy sources are subject to and performed in accordance with the requirements of this program and applicable regulations. Principal investigators are responsible for activities in their assigned areas/program. These responsibilities include:

    • Identify all machinery, equipment or processes subject to this program.

    • Identify "authorized" and "affected" employees.
    • Ensure that all authorized and affected employees receive proper training on the LOTO Program.
    • Where applicable, develop, document and utilize written energy control procedures for each potentially hazardous energy source.
    • Ensure all new and refurbished equipment is capable of accommodating lockout devices.
    • Provide ongoing funding of the LOTO Program.
  • University Safety & Assurances in Conjunction with Facility Services will:

    • Develop and maintain this written program which complies with the minimum requirements of OSHA and DCOM.

    • Assist in employee training.
    • Assist departments in identifying hazardous energy sources and choosing of proper LOTO methods.
    • Perform periodic inspections to ensure compliance with program goals and objectives.
  • All Authorized and Affected Employees are required to:

    • Follow LOTO procedures.

    • Lockout/tagout or provide machine guarding.
    • Not start, energize or use equipment, machines or processes that are locked out or tagged out.
    • Identify hazardous energy sources and report these to their supervisor.
  • Questions regarding the UWM LOTO Program shall be directed to your immediate supervisor. In some cases assistance from other shops or departments may be necessary.
  • Concerns or incidents regarding the UWM LOTO Program shall be reported to your immediate supervisor or safety committee. Incidents shall be reviewed by your supervisor and/or the Safety Committee. Where necessary, corrective follow-up action or modification of the program shall be implemented.

Training Requirements:

  • Training requirements are specified in OSHA CFR 1910.147(c)(7) The Control of Hazardous Energy (lockout/tagout)
  • Employees shall be informed about the LOTO program requirements at initial hire and periodically thereafter.
  • Individual departments shall provide training to ensure that the purpose and function of the LOTO program are understood by employees (students) and that the knowledge and skills required for the safe application, use and removal of the energy controls are acquired.
  • Retraining shall be provided for employees whenever a change in their job assignments, a change in machines, equipment or processes present a new hazard, or when there is a change in the energy control procedures.
  • Additional retraining shall also be conducted whenever a periodic inspection reveals or whenever the department (employer) has reason to believe that there are deviations from or inadequacies in administrative practices or the employee's knowledge or use of the energy control procedures.
  • The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary.

General Requirements of the LOTO Program:

  • Basic Requirements:

    • Before the work phase of operation begins, an activity hazard analysis shall determine whether an employee may be exposed to unplanned releases of energy, hazardous material or unguarded machinery.

    • Supervisors shall provide single and/or multi-locking devices, tags and other items needed to comply with the program such as lockout hasps, circuit breaker lockouts, etc.
    • If employees have questions about their safety during lockout or tagout of equipment, they shall consult their supervisor.
  • Procedures for Lockout and Tagout of Equipment:
    • Equipment that might inadvertently release energy or hazardous material when turned on, and consequently cause injury, shall be locked out and/or tagged out.
    • Departments shall establish a system for employees to obtain locks, multi-locking hasps, tags and other LOTO devices. Employees shall be instructed of these procedures. Departmental representatives and specific departmental information includes:

      • Physical Plant Services-Shops: a LOTO kit including personalized tags shall be issued at time of hire. Additional or replacement tags may be obtained through Physical Plant Services.

      • Power Plant: Mark Peters
      • Sandburg: David Riesch
      • Union: Fran Jasper
      • Other administrative and academic departments: Programs are under development, please contact your instructor or supervisor.
    • Each employee must identify his/her locks in an individual way (e.g., name, photo, etc.)
    • A key to each lock issued to an employee shall be retained by the employee; the only other key shall be in the care of a supervisor and stored in a secure location.
    • Employees shall request assistance from their supervisor if they are not sure how to lock out equipment.
    • Departments shall identify which pieces of equipment need specific lockout procedures.
Reminder: Power or energy isolation control by locking out is the most accepted method of safety control [OSHA 29 CFR 1910.147(a)(l)(c)(2)(ii)].
  • Lockout of Power Sources:

    • Equipment and machinery including valves, flanges, switches, and similar items shall be locked out at the point of control, for example, at the switch box or valve. If it cannot be locked out at the point of control, it shall be locked out at the next feed source of energy supply.

    • Cord and Plug Connections:

      • The UWM LOTO program does not apply to work on cord and plug connected electrical equipment when the employee performing the service or maintenance has exclusive control of the plug.

      • Cord and plug connections that are out of sight shall be locked out at the energy source (for example, the breaker or disconnect feeding), and the employee's tag or lock shall be applied to the plug end of the cord.
    • After a power or energy source is locked out, the employee shall ensure by test or other allowed method that the energy source is isolated.
    • When two or more employees are working on the same equipment, each employee shall attach his or her personal lock to the lever, valve, switch, or disconnect (off) switch. An adapter or multi-locking device may be used to attach one or more locks to a single control mechanism.
    • An employee who is assigned to work on locked-out equipment shall place his or her lock and tag on the equipment and determine that there is no power to the equipment. Employees shall also check with others on the site about the status of the machinery if necessary.
    • Where necessary, employees shall arrange for jacks, blocks, or other safeguards to be in place along with the lockout.
  • Removing Locks and Tags and Restoring Power:

    • An employee shall remove only his or her own lock. When the work is completed, the equipment should be operable when the last lock is removed.

    • Power may be turned on to test or adjust the equipment. Each employee who has a lock attached to the equipment shall be advised of the potential danger before removal of his/her lock. All affected employees shall reattach locks after the equipment is tested or adjusted, unless the unit is ready to return to service.
    • Before removing the last lock from locked-out equipment the employee shall ensure that:

      • All guards have been replaced;

      • Equipment, machine, or process is cleared; and
      • Appropriate personnel are notified of power being restored.
  • Equipment Locks:

    • An equipment lock is used to replace employee lock(s) when equipment is to be locked out for an extended period.

    • Equipment locks and tags are issued by supervisors. Except for the markings, they are the same type of locks as those issued by the authorized employee. The name of the employee placing the lock on the equipment and the name of the authorizing supervisor shall be indicated on the equipment lock and/or accompanying tag.
    • Equipment locks must be identified by a recognized marking; an accompanying danger tag shall indicate why the equipment is locked out.
    • Before the supervisor removes the lock from the locked-out equipment, he or she shall ensure that:

      • All guards have been replaced;

      • Equipment, machine, or process is cleared; and
      • Appropriate personnel are notified of power being restored.
  • Requirements for Removing Another Employee's Lock:

    • Departments shall establish a plan for removing the lock of an employee who is absent.

    • When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed by the employer using a master key provided that the following conditions are met:

      • Verification by the employer that the authorized employee who applied the device is not at the facility.

      • Make all reasonable efforts to contact the authorized employee to inform him/her that his/her lockout or tagout device has been removed.
      • Ensure that the authorized employee has this knowledge before he/she resumes work at the facility.
    • Before removing the lock, the manager or supervisor shall ensure that those working on the equipment know that it was previously locked out. The equipment shall be power-tested and inspected; all requirements shall be followed for restoring power.
  • Control of Second Key:

    • The person with the highest level of responsibility shall have a second key to employees' locks.

    • Keys to employees' locks shall be kept in a secure location and made available only to the person with the highest level of responsibility on site. A record indicating that a second key has been removed shall be maintained on site. If a master key system is used with the second key system, the same control process shall apply.
  • Tags:

    • It is recommended that a tag stating DANGER-Do Not Operate, DANGER-Do Not Start, Do Not Open, Do Not Close, Do Not Energize or another appropriate warning be used along with the lock when equipment or machinery is locked out.

    • Tags shall be placed to clearly identify the equipment of circuits being worked on.
    • Tags shall be given the same level of respect and treatment as locks. However, please remember: Power or energy isolation control by locking out is the most accepted method of safety control since tags are warning devices which can be easily removed, bypassed, obscured or ignored.
  • Contractor Relations:

    • Contractors and vendors who perform work at UWM must adhere to minimum OSHA requirements.

    • The LOTO program shall be explained to contractors working at UWM. Contractors shall also inform UWM of their own LOTO procedures. UWM employees and contractors shall work cooperatively to ensure compliance with LOTO goals.
  • Exceptions / Exclusions:

    • An exception to the LOTO program may be exposure to electrical hazards from work on, near or with conductors or equipment in electrical utilization installations. Only qualified and authorized employees (e.g., electricians) shall be permitted to engage in such situations or operations.

    • An exception to the LOTO program may be minor tool changes and adjustments which take place during normal production operations if they are routine, repetitive, and integral to the use of the equipment provided that the work is performed using alternative measures which provide effective protection.
    • A written procedure need not be developed for a particular machine or equipment, when all of the following elements exist:

      • There is no potential for energy to be stored or reaccumulated after the shutdown.

      • There is a single, readily identifiable source of energy isolation, and the isolation completely de-energizes the equipment.
      • The machine is locked out during service.
      • Application of a single lockout device provides a complete lockout condition.
      • The lockout device is under the exclusive control of the employee performing the work.
      • The maintenance or service does not itself create a hazard to other employees.
      • There have been no accidents or incidents involving the unexpected activation of machines during service or maintenance.
  • Definitions:

    Activity Hazard Analysis:

    Risk assessment or hazard analysis performed for a specific task.

    Affected Employee:

    An employee who is required to use machines or equipment on which servicing is performed under the OSHA Lockout/Tagout standard or who performs other job responsibilities in an area where such servicing is performed.

    Authorized Employee:

    An employee who locks or tags machines or equipment in order to perform servicing, maintenance, inspection, etc.

    Energy Control Device:

    A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: A manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices.

    Energized:

    Machines and equipment are energized when they are connected to an energy source or they contain residual or stored energy.

    Energy Source:

    Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.

    Lockout:

    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.

    Other Employees:

    All employees who are or may be in an area where energy control procedures may be utilized. This may include contractors or other building occupants such as faculty and students.

    Primary Authorized Employee:

    A person designated to exercise primary responsibility for the implementation and coordination of LOTO in a given scenario.

    Residual Power:

    Energy which is retained in a system, machine or unit when the supply line disconnect is placed on the OFF position. Power capacitors and electric or magnetic fields are examples that may have residual power if not properly dissipated.

    Residual Pressure:

    The differential pressure remaining within a component after the pressure source is closed off.

    Tagout:

    The placement of a tagout 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 tagout device is removed.

    Tagout Device:

    Any prominent warning device, such as a tag and a means of attachment, that can be securely fastened to an energy-isolating device to indicate that the machine or equipment to which it is attached may not be operated until the tagout device is removed.

References:

Updated April 8, 2008 by SAK