When LOTO isn’t the only answer

In this installment of Automation Zone, alternatives to lockout/tagout can offer safety as well as savings.

By George Schuster & Jimi Michalscheck, Rockwell Automation

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When OSHA released its latest annual list of the 10 most-cited workplace safety violations, few people likely were surprised to see lockout/tagout (LOTO) make the list yet again.

For 2015, LOTO came in at No. 5. That’s the same spot it held 10 years ago, although the actual number of cited violations has dropped markedly from 3,711 in 2005 to 3,002 in 2015. And although no safety violation is excusable or defensible, it’s easy to understand why LOTO has become such a perennial problem.

The LOTO procedure, in which maintenance workers must remove power sources to a machine before they service it, can be both time- and labor-intensive. This can take a toll on productivity and create a strong incentive for workers to bypass LOTO when they need to perform certain maintenance or repair tasks, especially on lines where stoppages such as machine jams frequently occur.

Furthermore, some types of diagnostic and setup work require active power sources, leaving maintenance technicians with no option other than to bypass LOTO to complete their tasks.

Fortunately, advances in safety standards and technologies have created opportunities for manufacturers and industrial operators to use alternative measures in place of LOTO for certain minor servicing tasks. The use of alternative measures can help reduce the likelihood of maintenance technicians attempting to bypass critical safety procedures; these measures can help reduce safety risks and boost productivity at the same time.

Openings for loto alternatives

Two separate standards provide for the use of alternative safety measures.

OSHA standard 29 CFR 1910.147 outlines alternative measures that can be used in certain circumstances to safeguard machines and devices without having to completely cut off the power source, allowing authorized workers to perform a prescribed service. ANSI/ASSE standard Z244.1-2003 also allows for the use of alternative measures in place of LOTO for tasks that are considered “routine, repetitive, and integral” to the operation of equipment during production.

It’s important to note, however, that these two standards aren’t fully harmonious. For example, the ANSI standard allows for alternative methods in certain situations where the OSHA standard would still require LOTO. The best approach for dealing with these discrepancies is to make sure the LOTO alternative complies with both of them.

Any alternative measure used in place of LOTO must first be carefully assessed – as part of a comprehensive risk assessment – for its effectiveness in the context of the machine’s configuration, the safety measure’s reliability, employee training, and other factors. If the measure doesn’t offer protection as effective as LOTO, it should be considered noncompliant and therefore insufficient to replace LOTO.

Benefits of loto alternatives

Alternative safety measures that meet OSHA and ANSI requirements can help enhance workplace safety by reducing opportunities for maintenance technicians to put themselves at risk. At the same time, the technologies used in place of LOTO can help improve productivity by reducing the need for maintenance workers to shut down and restart machinery during minor servicing.

For example, safe-speed technologies can allow a maintenance technician to open a machine’s safety door and make adjustments while production continues at a reduced speed. The technician can watch the direct results of adjustments as they’re made rather than having to continually shut down and restart the machine for each adjustment until the issue is resolved.

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  • Not sure about this. I believe the unofficial mantra of OSHA is "someone gets hurt, someone's getting fined" and it wouldn't matter if ANSI or any other document said it was ok. Let us not for get that OSHA is "LAW" . It takes an act of congress to add. change or move any article in the book. And it's back by the supreme court!

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  • When LOTO came in service,a few years ago in connection with oshas as a safety point of view,and most of the hazardous plants follow the same.But it is not only the solution to support the maintenance,and also productivity,each and every person who involved in the operation of process must thoroughly know the severity of the plant safety and process knowledge,then only these types of problems can be solved

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  • OSHA’s Minor Servicing Exception provides that some servicing operations performed during normal production operations are excepted from coverage under the Lockout/Tagout standard, provided that associated danger zones are properly guarded. The machine guarding standards in Subpart O cover these types of operations. The Lockout/Tagout standard contains specific criteria that must be met for the minor servicing exception to apply. Minor tool changes and adjustments, and other minor servicing activities that take place during normal production operations, are not covered by the (LOTO) standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection. If the servicing operation is routine, repetitive, and must be performed as part of the production process, the employer must use alternative protective methods or safeguarding devices (such as remote oilers and specially designed servicing tools), to protect employees. The key issue is that the minor servicing exception may not be used to simply disregard associated risks. More information is available here https://www.osha.gov/dts/osta/lototraining/hottopics/ht-relche-1-2.html In all cases, the basis for “effective protection” begins with a formal risk assessment to determine the risk reduction targets necessary for the “alternate measures”. If all the requisite criteria apply, the employer must use alternative measures to provide effective protection from the hazardous energy. Some acceptable alternative measures include specially designed tools, remote devices, interlocked barrier guards, local disconnects, or control switches which are under the exclusive control of the employee performing the minor servicing. These alternative measures must enable the employee to safely perform the servicing task without being exposed to the unexpected energization or activation of the equipment, or the release of stored energy. When implemented in compliance with OSHA, the Minor Servicing Exception and Alternate Measures provide an effective means to protect employees while enabling the production process.

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