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5:27 pm
September 13, 2017
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Explore Alternative LOTO Measures

Industry is fast embracing the concept of alternative measures when it comes to compliance with OSHA and ANSI guidance on lockout/tagout. Examples include using key-controlled locks, control switches, interlocked guards, and remote devices and disconnects, among others. Locking out just a section of a machine is another approach. Photo courtesy of The Master Lock Co.

Industry is fast embracing the concept of alternative measures when it comes to compliance with OSHA and ANSI guidance on lockout/tagout. Examples include using key-controlled locks, control switches, interlocked guards, and remote devices and disconnects, among others. Locking out just a section of a machine is another approach. Photo courtesy of The Master Lock Co.

An alternate universe of lockout/tagout approaches has begun easing the struggle to comply with OSHA and ANSI standards.

On the surface, at least, machine lockout/tagout (LOTO) appears straightforward: Identify and isolate energy sources, lock and tag, and perform the procedure that needs to get done. Simple enough? Wrong.

When energy is required to complete machine diagnostics or set-up work, or when a minor maintenance job is going to throw production hours behind schedule, LOTO becomes something far more complex than a textbook explanation.

Given its intricacies, it is understandable why LOTO, as outlined in OSHA standard 29 CFR 1910.147 The Control of Hazardous Energy (Lockout/Tagout), has become an everyday struggle for many safety personnel—and why LOTO ranks among the Occupational Safety & Health Administration’s (OSHA) top 10 violations, year after year. It’s also understandable why industry is fast embracing OSHA’s Alternative Protection Measures.

OSHA requirements

OSHA 29 CFR 1910.147 requires employees to remove power sources to a machine that could otherwise result in personal injury, if energy were unintentionally released during maintenance or service. It clearly states facilities are responsible for establishing a written program covering how required safety measures will be applied. This includes provisions for developing machine-specific energy-control procedures, training authorized workers to protect themselves regarding LOTO, and conducting periodic inspections of the adequacy of the written procedures, along with the performance of personnel applying them.

As comprehensive as LOTO may be, it can be very time intensive, often requiring longer than is required to finish the actual maintenance task. Processes come to a halt, resulting in the possibility of the day’s production numbers being missed. This situation becomes even more frustrating when the maintenance task is one that must be implemented several times a day. Loss of time and profits creates strong incentives to bypass LOTO when performing repetitive machine tasks. Disregarding these procedures, however, violates OSHA requirements and puts workers in danger.

Thankfully, OSHA 29 CFR 1910.147 also outlines Alternative Protection Measure (APM) procedures that can result in increased efficiency without compromising the safety of the operation. This exception is also referred to as the minor servicing exception. Designed for machine tasks that demand repetitive access, i.e., clearing a jam on a conveyor or a minor tool change, alternative measures do not require that power sources be completely cut off. Examples of alternative-measure technologies include key-controlled locks, control switches, interlocked guards, and remote devices and disconnects. Locking out just a section of a piece of equipment, rather than the entire machine, is another approach.

ANSI requirements

The newest ANSI standard, ANSI/ASSE Z244.1 (2016) The Control of Hazardous Energy—Lockout, Tagout and Alternative Methods, agrees with OSHA in that workers should be protected from injury due to unexpected equipment startup or release of potentially hazardous energy. The ANSI committee, though, did not try to align fully with every historic OSHA compliance requirement. Instead, the new standard gives expanded guidance beyond OSHA’s regulatory limitation to tasks that are “routine, repetitive, and integral to production operations”.

ANSI makes it very clear LOTO shall be used unless a user can demonstrate that a well-established alternative method will provide effective protection. In situations where the task isn’t well understood or risk isn’t assessed, lockout shall be the default protective measure applied to control machinery or processes. Section 8.2.1 of ANSI/ASSE Z244.1 (2016) specifies that alternative methods shall only be used after hazards have been assessed and documented through the application of a Practicability (or Justification) Study to determine that the techniques used will result in a negligible risk or no risk for sudden startup.

Following the Hierarchy of Control model, ANSI/ASSE Z244.1 (2016) provides detailed guidance on if, when, and how a range of alternative control methods can be applied to result in equal or improved protection for people performing specific tasks. In addition, alternative risk-reduction methodology is covered in detail specific to a number of new technologies used in the packaging, pharmaceutical, plastics, printing, and steel industries, and for dealing with certain challenges in semiconductor and robotic applications.

Navigating the requirements

Since the OSHA and ANSI standards are somewhat conflicting, it’s best to review ANSI first to help identify discrepancies that may not meet federal minimum regulations.

At this point, it would be appropriate to underscore that LOTO provides the greatest level of protection and, whenever possible, it should be utilized to protect employees from hazardous energy. In other words, inconvenience alone is not an acceptable excuse to use alternative measures. In addition, CFR 1910.147 clearly states that an allowable alternative measure must provide the same or greater level of protection as LOTO. Otherwise, it is considered noncompliant and therefore insufficient to replace LOTO.

By using standard safety-rated devices, such as interlock gates and e-stop buttons, a plant manager can achieve safe, reliable machine access that replaces standard LOTO procedures without violating OSHA requirements. Implementing alternative procedures to ensure equivalent protection for specific tasks can enhance productivity without endangering employees. But those procedures—and their benefits—come with strings attached, requiring a thorough understanding of the latest OSHA and ANSI standards.  MT

Information was provided by Matt Brenner, a vice president at Rockford Systems (rockfordsystems.com, Rockford, IL), and Todd Grover, global senior manager of Applied Safety Solutions for The Master Lock Co. (masterlock.com, Oak Creek, WI). An ANSI board member, Grover helped write the Institute’s LOTO alternative-methods code.


For more information on applicable lockout/tagout standards, see:

Occupational Safety & Health Administration, Washington, OSHA.gov

American National Standards Institute, Washington, ANSI.org

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