Machine Safety and Lockout/Tagout
The lockout/tagout (LOTO) standard is an OSHA regulation for machine safety that establishes employer responsibility to protect employees from hazardous energy sources on machines and equipment during service and/or maintenance. According to OSHA, “Approximately 3 million workers service equipment and face the greatest risk of injury if lockout/tagout is not properly implemented. Compliance with the lockout/tagout standard (29 CFR 1910.147) prevents an estimated 120 fatalities and 50,000 injuries each year.” Every machine safety standard I’ve ever reviewed or helped to write has either normatively or informatively referenced this OSHA regulation. Since its inception, LOTO has changed very little with the exception that just a few years ago OSHA provided abbreviated requirements when conducting “minor maintenance” such as cleanup. Additionally, I can’t recall any company’s Safety Policy manual that did not call out requirements for LOTO.
So, with all this said, why is LOTO always on OSHA’s top ten list of safety citations or a topic of concern or discussion throughout industry here in the U.S.? It’s my opinion that this phenomena occurs because LOTO a procedure vs a built in (designed in) solution for machine guarding. Since LOTO is a maintenance procedure it’s also a key performance item built into the “safety culture” of each company. Therefore, the effectiveness of compliance with LOTO is a direct result of the strength and effectiveness of any company’s safety culture. And, as we all know, safety cultures vary considerably from company to company.
A new question also recently arises questioning if LOTO is still only procedural? It seems this question comes about as a result of the combined innovation of “safety automation” and the functional safety provisions of IEC 62061 and ISO 13849-1. With the application of safety PLC’s, safety drives, safe motion, and many more…….comments have come from manufacturing asking if these safety solutions have isolated some of the hazardous energy sources on a machine when the safety system shuts the machine down?
What is your opinion? Will safety automation lead to modifications in the LOTO procedure? Submit your ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don’t see a comments box, then scroll down: Machine Safey & Lockout/Tagout comments and questions.
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