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The Control of Hazardous Energy - Enforcement Policy &
Inspection Procedures
OSHA INSTRUCTIONCPL 02-00-147
Walt Siegfried CSP, MSOffice of General
Industry Enforcement
Occupational Safety & Health
Administration
2
WHY THE MANUAL?
Paramount importance!!! Unless it’s essential, eliminate
exposure to hazardous areas Techniques to avoid exposure:
o Interview in safe locationso Photograph from a safe locationo Use engineering drawings in
lieu of direct measurement
CSHO SAFETY
WHEN IN DOUBT STAY OUT!
CPL 02-00-147 Chapter 2 Section I
3
SAFE PRACTICES
If CSHOs must inspect areas with hazardous energy exposure, they are outside personnel o Paragraph 1910.147(f)(2) applieso Do not shutdown or isolate
machineryo On-site procedure training &
communicationo Group LOTO – apply LOTO deviceo Witness verification of isolation
4
WHY A MANUAL?
Frequently cited standardso 392 Federal fatality inspections w/
1910.147 violations (10/02 – 9/07)o 3rd most cited 1910 standard
(2007)
Establish uniform inspection procedures
Consolidate energy control policy
5
HOW CAN THE MANUAL HELP YOU?
Understand how to integrate & apply hazardous energy control standards
o 1910.1471910.147 (LOTO), including the minor servicing exception
o 1910, Subpart OSubpart O (machine guarding)o 1910.332 1910.332 & 1910.3331910.333 (electrical)o Vertical LOTO provisions (such as
permit-required confined space)
6
HYDRAULIC PRESS EXAMPLE
Hazardous energy control steps may involve…
Lockout (safety blocks, disconnect switch, hydraulic valve),
Safeguarding (2-hand control), and/or
Electrical safe work practices (by a qualified electrical person)
…depending on the servicing/maintenance task.
7
SUPPLEMENTAL ASPECT
1910.147 procedure & training provisions supplement other vertical LOTO standards to the extent that they are not regulated by the specific LOTO provision
Some other standards that have LOTO requirements:o 1910.146 - Permit-required confined spaceso 1910.179 - Craneso 1910.217 - Mechanical power presseso 1910.268 - Telecommunicationso 1910.272 - Grain handling
8
HOW CAN IT HELP?
Links key interpretations/legal decisionso Addresses enforcement strategies - e.g., unexpected
energization or startup Multi-employer policy scenarios
o IBP, Inc. Court of Appeals decision – consult SOL Affirmative defense scenarios
o Unpreventable employee misconduct and isolated instance; foreman misconduct; greater hazard; impossibility
Citation examples
CPL 02-00-147 Chapter 3 Section I
9
KEY DEFINITIONS
Hazardous Energy - Energy that could cause injury to employees
Servicing and/or Maintenance - Timken Company OSHRC decision note
o Equipment that functions separately is not part of the same equipment
CPL 02-00-147 Chapter 1 Section IX p. 1-14
10
KEY DEFINITIONS (cont.)
Authorized Employee: Employee who performs equipment service/maintenance or implements these procedures, including:
Performing energy isolation Implementing LOTO on equipment Dissipating stored energy Verifying isolation Implementing actions to release LOTO Testing or positioning equipment components
11
POLICY ISSUES
Scope & application Energy control programs
o Tagout programs Specific procedures Periodic inspections Group LOTO Vehicles Alternatives
12
SCOPE & APPLICATION
Normal production operations: Utilization of equipment to perform its intended production function o Usually covered by
Subpart O 1910.147 covers the control of
energy during machine servicing/maintenance where injury may resulto Both potential & kinetic
energy
CPL 02-00-147 Chapter 3 Section II p. 3-2
13
ENERGY CONTROL PROCEDURES
Control procedures must provide:
Sufficient detail and Specific guidance for the
energy control steps so that authorized employees clearly understand how to safely utilize control measures for the machine being serviced/maintained.
ABC Co.Energy Control Procedure
Purpose
______________________________________________________________________________
Compliance with this program ______________________________________________________________________________
Sequence of Lockout
(1)__________________________________________________
CPL 02-00-147 Chapter 3 Section IX p. 3-39
14
SPECIFIC PROCEDURES
OSHA retained the word specific in the final rule because overgeneralization does not provide employees with sufficient information to effectively control hazardous energy.
Generic procedures alone are unacceptable
Work permits, checklists, placards may be used to supplement generic procedures
15
PROCEDURE GROUPING
Similar machines/equipment may be grouped if they are listed in the procedure scope & all have the same or similar control steps to: Shut down, isolate, block, secure & dissipate stored
energy Place, remove & transfer LOTO devices &
responsibility for them Test a machine/equipment to determine & verify
effectiveness of control measures
16
PERIODIC INSPECTION COMPONENTS
Periodic inspection of each procedure (annually) Review employee responsibilities – Observe &
interview Authorized employees for LO Authorized & affected employees for TO
Purpose is to verify Procedure steps are followed Employees know their responsibilities Procedure is adequate
CPL 02-00-147 Chapter 3 Section XVII p. 3-65
17
STREAMLINED PROCESS
Inspect a representative # of employees implementing the procedure
Perform supplemental review with remainder of employeeso Used for same or similar machines/equipment
that have same or similar control measureso Reviews may be performed by group meetings
This approach is acceptable if the inspection sampling reasonably reflects hazardous energy control practices.
18
Personal Lockout -Tagout Devices
Satellite Lockbox/Tagbox
Group LockoutTagout Mechanism
Master Lockbox/Tagbox
EquipmentLockout-Tagout
AE
C
F
G H
B
P1
D
P2
CrewLeader
D
CG
A
Exchanger
P1
P1
P2
P2
B F
E
H
Personal Lockout -Tagout Devices
Satellite Lockbox/Tagbox
Group LockoutTagout Mechanism
Master Lockbox/Tagbox
EquipmentLockout-Tagout
AE
C
F
G H
B
P1
D
P2
AE
C
F
G H
B
P1
D
P2
AE
C
F
G H
B
P1
D
P2
CrewLeader
D
CG
A
Exchanger
P1
P1
P2
P2
B F
E
H D
CG
A
Exchanger
P1
P1
P2
P2
B F
E
H
TYPE C
GROUP LOCKOUT / TAGOUT
CPL 02-00-147 Chapter 4
19
VEHICLE HAZARDOUS ENERGY CONTROL
Vehicle servicing and maintenance activities have caused serious injury & death
1910.147 applies to general industry workplaces that service or maintain vehicles; such as: Automobiles Trucks Tractors Transport vehicles Material handling equipment
CPL 02-00-147 Chapter 3 Section III p. 3-22
20
PROGRAM FLEXIBILITY
An energy control program is necessary; however, due to nature & unique aspect of vehicle maintenance, the energy control measures must be tailored to the workplace. For example, sole control of ignition key
may provide protection in some, but not all, situations.
21
LOTO ALTERNATIVES
Machine guarding Cord & plug-
connected equipment
Control circuitry (variances)
Other abatement methods
CPL 02-00-147 Chapter 2 Section IV p. 2-15
22
MINOR SERVICING EXCEPTION
Limited exception! Work is minor in nature Routine & repetitive Performed during normal production
operations Integral to the use of the equipment
for production Work is performed using alternative
methods which provide effective protection
CPL 02-00-147 Chapter 3 Section IV p. 3-25
23
LEGAL DECISIONS
Westvaco Corporationo Work performed before the normal production
operation (NPO) is not covered by the MSEo Setting up prepares a machine to perform its NPO
and, by definition, does not occur during NPO
Falcon Steel Co. o Party claiming benefit of exception has burden
of proving scenario falls within exceptiono Document specific inadequacies (e.g. injuries)
with 1 or more MSE elements – i.e., to refute an employer’s claim that 1910.147 does not apply because of the exception
24
HOW CAN YOU USE THE MANUAL?
Protect yourself - CSHO safety practices
Apply enforcement policy & procedures Compliment other directives - e.g.,
amputation NEP, slide lock directive, die-set directive
Link to case law, interpretation letters, CSB & NIOSH incident reports
Locate references (Chapter 5) Education & training purposes
25
LEGAL SUFFICIENCY
Prima Facie Cited standard is applicable Employer failed to comply Employees were exposed Employer knowledge
Apply Enforcement flow diagrams Multi-employer policy Legal decision strategies
Refute Affirmative defenses Minor servicing exception
Building anOSHA 1B Form