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Honor Your Tagout Program and Save Lives

During a cultural assessment of a client we discovered that a flaw existed in the lockout/tagout (LOTO) program.  When I walked into the break room I noticed lunch boxes with anodized aluminum locks.  Knowing that they were locks that are used in the lockout program, I asked if we could visit the locker room and was granted access.  Sure enough, most of the lockers had lockout locks being used to secure the doors.  This is a violation.

In some companies you will find tags used for the tagout program used for everything from a shopping list to leveling the tables in the break room.  This is also a violation.  Why?  Because the purpose of these safety devices is degraded and improper use creates complacency in the workplace.  If the devices are not respected by employees who depend on them to stop someone from re-energizing a machine or circuit, then the tags may not be used properly when it counts most.

Companies are permitted to use either lockout or tagout, or a combination of both programs to provide a safe workplace.  No matter which program is used, the company must be able to demonstrate its ability to control the energy used in the workplace.  Employees are responsible for knowing, respecting, and monitoring the process.  If you find anyone using a lockout lock or tagout tag for any other purpose, stop them.  Explain to the offender that this is one of the most important safety processes inside your company.  If everyone in the organization will take this responsibility, your company will be well on its way to creating a workplace where Nobody Gets Hurt.

1910.147(c)(2)(iii)
After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device.
1910.147(c)(3)
Full employee protection.
1910.147(c)(3)(i)
When a tagout device is used on an energy isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.
1910.147(c)(3)(ii)
In demonstrating that a level of safety is achieved in the tagout program which is equivalent to the level of safety obtained by using a lockout program, the employer shall demonstrate full compliance with all tagout-related provisions of this standard together with such additional elements as are necessary to provide the equivalent safety available from the use of a lockout device. Additional means to be considered as part of the demonstration of full employee protection shall include the implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energizing.

 

Carl Potter, CSP offers a workshop that meets OHSA’s requirement for teaching employees hazard recognition skills.  Carl Potter’s Hazard Recognition and Control Workshop is a 6-hour presentation that is customized to your location, interactive and improve your organizations safety culture.  To find out more about having this workshop at your location email carl@potterandassociates.com and request a quote.

 

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