It seems like I find myself in a little bit of a safety niche lately with this column as well as the recent July column on how to establish an “Electrically Safe Working Condition.”
In July’s column I pointed out the eight-step process required by NFPA 70E to reduce electrical shock hazards while working on the electrical system or equipment. In this column I want to explore step number six of the ESWC. Locking off the electrical source and preventing it from being inadvertently re-energized. Tagging it with information of who is working on the equipment or circuit and why. I promise to get back to the National Electric Code next month.
As a representative of the graying side of this profession, I remember a time when electrical safety was often balked at by my predecessors. The seasoned Journeymen and Masters of the trade often mocked workers that had some fear of doing certain electrical work.
It typically meant you were scared or not “man enough” to do the job. Or it was thought that it may take too much time to comply with the requirements which would result in a delay. Or maybe you just think you are buying time? You might be saying, “If there was not an incident so far, why should I comply?” “I’m good!” Maybe, you think that this only applies to larger companies. Companies with more than ten employees. Whatever side of this discussion you fall on I hope to change your mind set on electrical safety moving forward. My hope is that as an employer or as an employee, you would embrace electrical safety and it’s benefits before it is too late.
The lure of danger while working on electrical systems was one of the reasons I chose the electrical field. In my 40 plus years of experience, I must admit, I have my share of stories that I am not proud of. Stories of putting my life and possibly the life of others on the line just to get a job or a specific task done.
As part of the eight-step process of the ESWC, we are required by OSHA and NFPA 70E, section 120.5, to apply a lock after de-energizing the electrical source of the disconnecting device and tag it with a message that the system is turned off for service, maintenance, or repairs and by who.
Having a compliant LOTO program goes beyond the locks and tags. Most OSHA citations are resulting from a lack of proper LOTO procedures, program documentation, periodic inspections or audits and other procedural components of your company documented LOTO plan.
LOTO is about saving lives. Too often a switch that has be turned off by an electrical worker was then closed by some other unauthorized person which results in injury or even death. It is not just confined to electrical energy but applies to all hazardous energy that might be part of the equipment or system that we work on. It is estimated that compliance with LOTO prevents about 120 fatalities and 50,000 injures each year.
There are two types of LOTO applications. A simple LOTO and a complex LOTO. See NFPA 70E section 120.4
A simple lockout/tagout is one where the individual is responsible for his or her own lockout/tagout. For example, If you needed to work on a sub-panel and must de-energize it, in accordance with NFPA 70E, you apply your lock and tag it to show others that you
have it off for your safety. The lock keeps others from closing the device and that tag puts a live person on the other end of the line. It shows that the breaker did not shut off automatically and should not be reset.
A complex LOTO is a procedure that is required where one or more of these conditions exists.
The processes and procedures for a complex LOTO should be part of your company’s LOTO documented policies and procedures. This must be provided to the employees by the employer. NFPA 70E is a good place to start. Training must be provided and documented at not more than three-year intervals. Approved LOTO devices and equipment must be provided by the employer. Qualified persons must be identified, and written plans must be documented and executed. Policies on when and who can remove another person’s lock must be addressed. What are the disciplinary actions for non-compliance? Policies on when LOTO may be relaxed when administrative tagging may be required for circuits when energizing will not result in a hazard to personnel or equipment.
I know some may think that LOTO might be a little over the top. But waiting until an incident that draws OSHA to investigate your place of employment will be too late to start with compliance. Not knowing how to implement your LOTO program properly will also result in costly citations. Moreover, having an injury or death after knowing it could have been avoided might put an employer in a legal battle that could result in criminal actions against them. A myth that some people think is that OSHA requirements only effect companies with 10 or more employees. This only applies to some injury and illness recordkeeping and reporting. Unless you are a sole proprietor or a family farm with only family working on it then you must comply with most all OHSA regulations. If you have an accident in your workplace that results in a death or if three or more people receive serious injuries from it, you must report that incident to OSHA.
More information on Lockout/Tagout is found in NFPA 70E and through OSHA. Many manufactures of LOTO products have very useful information when using their offerings. If you are, or your company is seeking compliance with the requirements of OSHA, NFPA 70E and specifically Lockout/Tagout, reach out to me for information on classes, customized training, or guidance in implementing an electrical safety policy from a certified professional for you and your employees.