|
A basic review of energy isolation
by PAMELA J. CORDIER
My position with the Pulp & Paper Safety Association allows me to hear many different opinions and concerns about safety within our industry. A significant number of those concerns relate to lockout/tagout (LOTO) or energy isolation. LOTO is a basic safety topic, and 29 CFR 1910.147 remains one of OSHA's most frequently cited standards since the hazards associated with failure to control or isolate all forms of energy can result in serious injuries or fatalities. But, if it is so basic and has the potential for such serious consequences, why is it so frequently cited for violations, and why are so many industrial injuries associated with LOTO? My conversations with both industry safety professionals and line supervisors indicate this question may have several different answers.
THE STANDARD FOR HAZARDOUS ENERGY CONTROL. As the standard for control of hazardous energy, 29 CFR 1910.147 has existed for a long time, and the potential for injury is readily apparent. While many aspects of the standard and its practical application are easily understood, others are vague and lend themselves to various interpretations.
Unfortunately, the concept of "zero energy" does not always lend itself to production processes in our industry, particularly in some machine setups where control power is required and in routine interruptions where lockout of main power is impractical. The OSHA standard does allow for exceptions to the lockout requirements for minor servicing activities provided that they are routine, repetitive, and integral to the production process. In these cases, we must implement alternative measures that provide effective protection for employees exposed to the potential hazard. Apparently, some facilities recognize these exceptions to the LOTO standard, but fail to implement procedures providing effective protection.
Also, one safety professional indicated that in his experience, it was the terminology and not the procedure that was to blame. He found that the alternative procedure providing effective protection was properly used, but that machine operators at his facility still called it lockout/tagout even though they were using control power.
OSHA, of course, does not recognize electrical energy isolation any place other than main disconnects. Machine operators must learn that these minor servicing activities are, in fact, alternative measures and are not LOTO. The safety professional I spoke with has coined the phrase "energy safe procedure" to differentiate these activities from LOTO. Another company uses the term "zero energy system," and another uses "safeguard key switches system."
ENFORCING LOCKOUT/TAGOUT PROCEDURES. In some cases, employers carefully train their employees on LOTO procedures but establish that their maintenance personnel are the "authorized employees" and, as such, are the only ones directly involved with energy isolation. All others are trained as "affected employees" or those that use the alternative measures.
However, it has been found that some employees take the concept of minor servicing activities far beyond the scope and intent of the exception to the standard. As one safety person put it, "Supervisors must realize that it is not who is doing the job that counts, but rather what job is being done."
Anytime the task goes beyond a routine, minor servicing activity, LOTO is required, regardless of who performs the task. Another concern has been raised over the actual terminology of lockout/ tagout itself. For some reason, the term LOTO conjures up images of electrical energy, although the OSHA standard covers all aspects and all types of energy, including steam, hydraulic, pneumatic, residual, and even gravity. To change this concept, some companies have started using terms like "energy isolation" or "zero energy" to more clearly define what LOTO encompasses.
Of universal concern is what to do when employees continue violating LOTO procedures or fail to use proper alternative measures, despite seemingly adequate training. This scenario is common and is difficult to manage. Some companies have unyielding policies and stringent disciplinary measures for violation of LOTO procedures, but as I have asked in previous columns, do we know for sure that our LOTO training is current, applicable, and practical? Is the training and observed safe behavior refreshed and reinforced, or is it a once-a-year regulatory mandate? Are we conducting periodic inspections as required by the OSHA standard? Are we sure that it is a clear-cut policy violation or did our system fail?
If we do a comprehensive hazard analysis, write concise and easily understood procedures, adequately train all authorized and affected employees, observe and evaluate our procedures, and then constantly reinforce them, we will establish the safe way to do the job. Employees that perform these tasks should be part of the implementation process. Energy isolation is a serious safety procedure, and the potential for injury or loss of life is enormous if shortcuts are taken.
|
