Lockout-tagout (LOTO). The OSHA Regulations
In a previous post, in which we looked at lockout-tagout (LOTO) for industrial safety, we saw that the origin of these procedures can be found in the rules drawn up by the US Occupational Safety and Health Administration (OSHA) in 1989.
The rule directly related to lockout-tagout is OSHA Regulation 1910.147 on the control of hazardous energy, which, over the years, has become the international standard for LOTO procedures and device requirements.
According to this regulation, the products used in lockout-tagout (including the lockout devices themselves as well as the padlocks and LOTO labels) must meet the following requirements:
• They should be clearly identifiable. This is why lockout-tagout products are given bright colours, so they can be identified from a distance.
• They should only be used for controlling the energy sources of company machinery and equipment. You simply need to hold a LOTO padlock in your hand to realise that its design and materials don’t give it the same level of security as any standard padlock. These devices are used to lockout the specific machine or equipment, not prevent theft.
• They should be durable and resistant, as well as easy to install. This refers to resistance to high temperatures and chemical agents, for example, as well as ultraviolet rays and electricity conduction. In other words, they should be able to withstand the energy sources they intend to lockout.
Working towards a lockout-tagout programme at the company
OSHA Regulations also state that the companies where maintenance and repair work will be carried out on machines and equipment should have a lockout-tagout programme in place that consists of the following three basic aspects:
• Energy source control procedures, so that the workers involved in these tasks know exactly what to do with each machine or equipment at the facility.
• Employee training so they implement LOTO procedures correctly and ensure this knowledge is updated over time.
• Regular inspections, ideally one or two per year, to ensure that procedures are implemented correctly.
International lockout-tagout regulations panorama
Over the last 20 years, lockout-tagout practices have spread from the United States to the rest of the Americas and, from there, to Europe, where more and more industrial companies are applying them in their occupational risk prevention procedures.
We said that OSHA Regulation 1910.147 has become standard because it was the first in the world to govern lockout-tagout practices. Nonetheless, the law in an increasing number of countries is now starting to consider these procedures either expressly or in a de facto manner. In the European Union, EU directives mention them in their recommended occupational risk prevention practices.
One example can be found in Spain, in Spanish Royal Decree 1215/1997 of 18 July, which establishes minimum health and safety provisions for the use of work equipment by workers. Section 1.14 of its Annex II states:
“Any maintenance, adjustment, unlocking, revision or repair operations on work equipment that may pose a hazard to the safety of workers must take place after the equipment has been shut down or disconnected, checks for the presence of any hazardous residual power are carried out and all the necessary measures to avoid the accidental start-up or connection thereof while the operation is being carried out have been taken. Whenever shut-down or disconnection is impossible, all the necessary measures to ensure these operations are carried out safely or away from hazardous areas must be taken”.
This resonates perfectly with the steps of the lockout-tagout (LOTO) procedure, which we will describe in a future post.