A significant portion of our machine guarding investigations involve situations where machine guards need to be removed and/or workers must place their hands within a machine’s point-of-operation. The scope of these investigations will typically go beyond an evaluation of mechanical or electrical guards to include administrative protections such as lockout/tagout procedures.
In this article, industrial engineer Harry Ehrlich provides an explanation of lockout/tagout within the context of industrial safety.
Machine Guarding & Lockout/Tagout - Expert Article
Adequate guards serve their purpose well and prevent needless injuries. However, there are times when guards must be removed. This typically occurs during maintenance, when workers are servicing or maintaining machines and equipment. Such tasks will require disassembly or partial disassembly of equipment, including the removal of guards.
In such situations, a worker may “turn the machine off,” using the controls provided on the machine. However, hazardous energy may remain. Such energy includes electrical, mechanical, hydraulic, pneumatic or other forms of energy present in the equipment.
Failure to control hazardous energy accounts for 10% of serious industrial accidents. A jammed conveyor system suddenly releases, injuring a worker who is trying to clear a jam. Internal wiring electrically shorts, shocking a worker who is repairing the equipment. A worker turns on a machine, unaware that another worker is under the machine making a repair.
A simple and feasible procedure to protect workers from hazardous energy is “Lockout/Tagout.” The Lockout/Tagout procedure may take several forms. The procedure may be as simple as locking the handle on an electrical panel or chaining the wheel on a steam valve. In either case, a lock with a unique key is utilized and that key remains under the exclusive control of the worker. A tag is applied at the control, to inform others of the lockout condition. Under certain conditions, other types of energy control may take the form of personal protective equipment or the “inch-safe-service” method used for printing presses. For items that are not hard-wired into a panel box, a plugout device may be used. An example is shown below.
Lockout/Tagout is mandated by OSHA Regulation 1910.147 The Control of Hazardous Energy. Selected sections from OSHA 1910.147 have been provided below for your reference. The complete regulations for General Industry can be accessed here.
- 1910.147(a)(1)(i) - This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy.
- 1910.147(a)(3)(i) - This section requires employers to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees.
- 1910.147(b) - Definitions applicable to this section.
- 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.
- Lockout device: A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.
- 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: A prominent warning device, such as a tag and a means of attachment, which can be securely fastened to 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.
- 1910.147(c)(1) - Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any 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.
Additionally, Lockout/Tagout is supported by the American National Standard ANSI Z244.1 Control of Hazardous Energy, Lockout/Tagout and Alternative Methods. ANSI standards are copyrighted and can be acquired through their webstore.
Robson Forensic possesses an extensive technical library that houses standards and reference materials dating throughout the modern industrial era. In many forensic investigations, our experts are able to reference industry specific resources to establish the relevant standard of care at the time that a piece of machinery or equipment was designed, built, or modified.
Workplace Safety & Machine Guarding Investigations
The industrial safety experts at Robson Forensic have designed, built, maintained, and operated a broad variety of industrial machinery. Moreover, our experts have investigated countless mishaps over the years. By retaining Robson Forensic, you are securing the full weight of our collective experience, knowledge, and resources toward the resolution of your case.
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Industrial Engineer & Machine Safety Expert
Harry has worked as an Industrial Engineer since 1978. He has been responsible for the design and manufacture of consumer products, as well as commercial and industrial equipment. Harry provides technical investigations, analysis, reports, and testimony toward the resolution of litigation involving product liability, and mechanical, industrial and construction accidents.
Harry has extensive experience in the area of compliance with safety standards; he has worked closely with Underwriters Laboratories, Canadian Standards Association, as well as overseas safety agencies. He has been responsible for product development, product testing, Quality Control, as well as factory floor safety. He has a broad background in machine guarding, industrial safeguards, personal protective equipment, training, and supervision.