Wednesday, March 13, 2013

Meet OSHA LOTO Standards with Regular Periodic Reviews: Guest Blog

by Danielle Gallo, Product Marketing Specialist and Heather Marenda, Compliance Services Engagement Manager - Brady Corporation

Last October, OSHA published their annual Top 10 "Most Frequently Cited Standards" list for fiscal year 2012. Once again, 29 CFR 1910.147 - The Control of Hazardous Energy (lockout/tagout) made the list. This regulation has been in force for more than 20 years and consistently appears on this list. So what are employers and safety managers missing?

One area where many companies fall into trouble is the periodic inspection element, found in 1910.147(c)(6). According to OSHA, periodically means "at least annually." Do you look at your internal lockout/tagout (LOTO) machine-specific procedures at least once a year to determine if any part of that process has changed? And if your equipment or process has changed, do you have a process to update the procedure at that time, instead of waiting?

1910.147(c)(6)(i): The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.

Part of this periodic inspection requires that an inspector review the procedure with "each authorized person." Authorized persons are those persons who perform the preventative maintenance, testing, calibration, or inspections of equipment. This review is a critical part of the Control of Hazardous Energy regulation, as well as your employee's safety. All inspections must be properly documented and recorded with the findings, as well as any action items must be addressed in a timely manner.

Not only are machine-specific LOTO procedures mandated by the OSHA regulation, but when effectively and visually displayed in a facility they can have drastic improvements in your workplace. Machine-specific procedures can:
  • Reduce employee training time
  • Reduce machine/equipment down time
  • Increase the overall productivity of a process, and boost morale, by helping employees understand what they need to do to keep themselves and their co-workers safe
To make compliance with this portion of the regulation easier on yourself, incorporate a review of your lockout procedures every six months as part of preventative maintenance programs. By instituting these regular reviews you'll be meeting the minimum OSHA regulations, very likely following the equipment manufacturer's recommendations, and keeping your employees safe in the process.

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