OSHA 1910.147 STANDARD

OSHA 1910.147 STANDARD (Hazardous Energy Control, Lock Out, Tag Out)

It is a ‘lock out and tag out’ method that must be implemented in order to prevent employees from the injuries that may be caused by an unexpected start of any machinery or equipment, or a discharge of a hazardous substance.
An unexpected start of any machinery or equipment may cause severe occupational accidents that may even result in death. The most appropriate way to prevent it is to lock out and tag out the machinery or process lines before operations like maintenance or repair (e.g. cleaning the moving parts of the equipment, loosening the moving parts that are trapped, removing the equipment protectors).
Normal production operations are not covered by this standard.
The maintenance, repair operations done during normal operations are covered by this standard.
There is a requirement that every person involved in the use, servicing and maintenance of the machines and equipment that may cause injury with an unexpected activation, operation or the release of stored energy, to apply a LOTO lock to the equipment. LOTO locks must be identifiable to the individual and their specific control area.
The employees are excluded from the requirement of LOTO for small service operations where an alternative, effective protection method is used.
All the requirements below must be met for this exception to be applied:

  • The procedures must be carried out during the normal production operations including the unblocking, short-scale cleaning, adjustments or lubrication without any injury risk in cases requiring no comprehensive demounting, and they must be specific to these operations.
  • The procedure must have these following characteristics:
    • Routine (a regular procedure and is compliant with the created applications)
    • Repetitive (repeated as a part of the production operation or cycle), and
    • Integrated (specific to the operation in question)

For this exception to be valid, a certified risk assessment must be undertaken as specified in the standards and appropriate protection must be ensured for the identified risk level.  

Aim:
This standard identifies the requirements for controlling the energy when unexpected operation can cause injury during working on or around the machinery and equipment (including, but not limited to, making adjustments, eliminating congestion, servicing operations, or maintenance).
Definitions:

1.     Affected Employee: 
The personnel working on the machine in an area where lock out and tag out procedures are applied as a result of the maintenance or service operations of such machines, equipment or systems.

2.     Authorized Persons:
The persons setting the lock out – tag out systems up during the maintenance or service operations of the machines, equipment or systems. In case the service and maintenance operations are implemented following the lock out and tag out procedures on the relevant machinery or in the relevant area under the responsibilities of the affected persons, the authorized persons and the affected persons may be the same.   

3.     Case with no energy:
The case where there is no power connection or potential energy

4.      Energized equipment:
An equipment having a power supply, residual energy or stored energy.

5.      Electrically Safe Operating State:
The state where the operation will be carried out on or near a conductive or circuit part that are disconnected from the electrical parts, are locked out/tagged out according to this procedure and tested to ensure the absence of voltage and grounded, if necessary.

6.      Power source:
Electrical, mechanical, heat, hydraulic, pneumatic, chemical and all other kinds of energy

7.       Lock out:
The process ensuring the isolation of the energy on the machinery and equipment with the use of locking device and only allowing to restore by removing this device.

8.       Locking device:
The devices ensuring the isolation of the energy when mounted on machines and equipment

9.       Simple equipment replacement:
Routine, repetitive, and complementary simple equipment replacements required during normal operation. Lock out - tag out is not required under these conditions.

10.     Tag out and tag out device:
Tag out procedure by tag out device to ensure informing personnel on the isolation by locking the energy of the machinery and equipment.

11.    Normal Operation:
Refers to the performance of the expected production function by the equipment or machinery. Locking has been removed on the equipment or machinery and re-energizing has taken place.

12.    Maintenance and Check: 
Refers to the check and maintenance operations to be carried out by the operating or maintenance personnel under operating, planned or failure conditions.
The scope, aim, authorization, rules, techniques on hazardous energy control must be explicitly indicated in the LOTO procedure.
In order to control hazardous energy; de-energizing steps, isolation, blockage, machine safety or equipment steps must be indicated.
Responsibilities of replacement, removal or transfer of the locking equipment must be indicated.

Characteristics of Locks and Tags:

1)  Locks:
Must be distinguishable from all other locks in the plant (specific shape, color and/or type).
LOTO locks must not be used for the purposes other than energy control.
The personal locks must be locked individually and the locks must be fully under the control of the person applying the lock.   
Personal identifiers must exists on all personal locks during usage (name tags, identity tags or engravings).  

2)  Labels:            
The tags used for LOTO must be uniform, resistant against being easily removed and attached to the lock. The tags must be placed at a point where it is possible to attach the lock when locks are not used, and if it is not possible, the tag must be placed on the energy isolation point.  
If it is not possible, the tag must be attached as secure as possible on a place to be immediately noticed by the person attempting to start the device.  
The tags must bear appropriate warnings such as “DO NOT START”, “DO NOT TURN ON”, “DO NOT ENERGIZE”.  
The tags must be understandable for the affected persons, authorized persons and other personnel.   
The tags must be durable within the environmental conditions of the plant.  

3) Locking Equipment: 
The locking equipment must be sufficiently durable against breakage and resistance when used with locks, switches or valves.

Periodic Inspections:
It is a defined procedure and requires the observation of the lock out procedures regarding the operation periodically by the managers to ensure compliance with the LOTO. All violations must be investigated and necessary action must be taken.
The equipment- and machine-specific procedures and instructions - must be reviewed,  especially following the preventative maintenance operations in terms of proper functioning of the system. These instructions must demonstrate that the necessary protections and identifications in the relevant area have been carried out correctly. In case a change or revision is necessary, the relevant person in charge must make this change.

Implementation of the energy control procedure:

1. Preparation for De-energizing: 
Authorized person, affected or authorized persons identify the lock out/tag out procedures to determine how (and in which order) the energy isolation procedures must be implemented and for the requirements of any kind of special equipment and personal protection equipment.

2. De-energizing the machinery or equipment:
The machine or equipment must be de-energized in accordance with the identified procedures.  

3. Isolation of the machinery or equipment:
The equipment is isolated from all power supply sources by using the isolation devices provided by the manufacturer (electricity, pressure, heat, etc.).

4. Lock out or tag out Application:
The lock out – tag out equipment must be attached on all energy isolation points by authorized persons.

5. Discharging the Residual Energy:
The equipment isolation devices cannot guarantee that there is no remaining energy in the equipment. The residual energy must be discharged.

6. Check:
It must be confirmed that there is no energy in the machine or equipment.

Removal of Lock out – Tag out Equipment:  The following checks must be carried out by the authorized person before removing the lock out – tag out equipment.

1. The machine or equipment is inspected for tools and materials or loosened components. The area must be checked to ensure that all the components are connected correctly once the unnecessary objects (such as hand tools and spare parts) are removed from the equipment and its surroundings.

2.  All the relevant personnel are informed that the repair and maintenance is complete and the equipment is ready to use. It must be ensured that all the personnel in the working area are kept at a safe distance. All the personnel must be warned to stay away before re-energizing.

3. Each lock out – tag out device must be removed by the person who implemented the locking procedure.

Group Locking:
The authorized person places all the lock out /tag out devices keys inside a box and then attaches a personal padlock to close this box.
Then, each person working on the equipment attaches their own padlocks to the box.
Thus, the box can only be opened and the equipment can only be commissioned by the lock out/tag out Manager when all the padlocks are removed.

Shift Change:
Shift change is done at LOTO implementation points. Newly arriving personnel check whether the locking is done according to the visual LOTO site instructions.

  • The personnel that have completed the work, removes the personal safety lock and tag.
  •  When the work is not finished at the end of a shift, a common area lock is used. The key is delivered to the newly arriving personnel after the attachment of the lock.
  • Newly arriving personnel remove the common area lock and attaches the personal lock and tag.

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