Does anybody know if osha is writing citations to employers for not posting written lockout/tagout procedures on every machine?  I have heard that they are writing citations for this under the general duty clause based on national consensus standards.

Your opinions would be greatly appreciated,

Brandon

Safety Manager

Lockout procedure postings will generally be viewed as "at risk" procedures. From my audits I have looked at what danger are your employees up against. A tilt table may not need a posted procedure, because it has little risk associated with it compared to a packaging machine. HOWEVER, if you have a tilt table that is battery pack powered (in addition to electrical plug), then someone unplugging it does not totally remove the battery power. I would post this equipment because the potential for someone forgetting or not knowing that there is a battery backup could put employees "at risk". In all of the plants that I service (over 25, up to 3 1/2 million sq ft), we post just about everything... General lockout postings can be very simple or very complex, depending on your companies policy. Be prepared to defend yourelf if you don not have something posted. Work with your maintenace people when you do machine reviews. Do you want to just comply, or do you want to make the best effort to protect your people..? When you look at a machine, you should assess the associated risk, then decide if you need a procedure.  I feel you need to protect yourself and your employer with a posted lockout procedure. You will find that most auditors will have different backgrounds and the one that lets you pass this year may not be the same one next year, and cause you a big headache (or if an accident occurs) Remember, you are not JUST protecting the employees, but yourself from negligence in the event someone is seriously injured.

LOCK OUT TAG OUT REQUIRES A MANDATORY WRITTEN PROGRAM.

 

THERE WERE 572 VIOLATIONS FOR NO WRITTEN POLICY WRITTEN IN 2006.

556 VIOLATIONS FOR PROCEDURES

 

448 VIOLTAIONS FOR TRAINING, LACK THEREOF

 

342 VIOLTATIONS FOR NOT CONDUCTING PERIODIC INSPECTIONS.  YOU MUST CHECK THAT YOUR LOTO PROGRAM IS ACTUALLY EFFECTIVE AND WELL UNDERSTOOD AND IT MUST BE DOCUMENTED!!!!!!

 

AND 188 VIOLATIONS FOR CONTENT OF THE LOCK OUT TAG OUT.

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"Safety First, Safety Always"


CSP, CDS, CIH

If you read the OSHA CFR Standard 1910.147 (c) this is why they are getting cited the employer has to establish a program consisting of energy control procedures, employee training and do periodic inspections to ensure that before any employee performs servicing or maintenance on a machine or equipment where the unexpected energizing, startup, or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

Thank you for your response,

I know that the employer has to establish a program consisting of energy control procedures and document these procedures, but I learned in a recent osha 10 hour class that employer has to actually attach these procedures to the machine or they can be cited.  It doesn't say anywhere in the 1910.147 standard that these procedures have to be posted on the machine.  It just says that the procedures must be documented.  This is the reason for my confusion.  Any responses are greatly appreciated.

Thank you    

There isn't a standard that says "You Must" put any step by step method to isolate eneregy, wether it be gas, steam, chemical, air pressure,steam eneregy, but  there should always be a step by step method to control all eneregy.  I do suggest that you do post it on the machine or have a book with those step by all machines.  We used to call in the army by the numbers from 1- 100000 how to isolate all sources of eneregy prior to working on a machine, a forklift, a circuit breaker, etc etc. 

 Also I think this is key, remember just because OSHA or anyother Federal agency puts a standard in place, does not mean you can not make that standard more strigent to protect life limb and property.  OSHA writes the standards, but OSHA does not tell you how to implement them, the implementation is on you.  The standards are the bare minimum, you can always add on but never take away from a standard.   

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"Safety First, Safety Always"


CSP, CDS, CIH