Do you know who your authorized employees are? Do you have employees performing service and maintenance on machinery without adequate authorized training and exposure controls?
Safety consultants often see employees performing servicing and maintenance activities on machinery and equipment without proper lockout compliance because the employer does not see some workers as authorized employees under OSHA's standard for controlling hazardous energy. Examples are equipment operators, employees helping maintenance personnel, cleaners, lubricators, employees working with contractors, or supervisors evaluating work being performed on machinery.
Here's OSHA's definition of Authorized Employee: A person who locks out or tags out a machine or equipment to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under 1910.147.
OSHA's 1910.147 lockout standard requires lockout compliance under the following conditions: "1910.147 (a)(2)(ii) An employee is required to remove or bypass a guard or other safety device; or an employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle."
When evaluating your employees to determine who the authorized employees are, you must consider the terms “servicing and maintenance".
Lockout activities are mandatory during "servicing and/or maintenance". These include activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities also include lubrication, cleaning or removal of a jam in a machine or equipment, and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or a release of hazardous energy.
Are your workers performing tasks that require lockout? Are they putting their bodies in harm's way if an unexpected energization of the machine occurs? Are they removing guards? If so, then we must reconsider who the authorized employees are. Failure to do so could lead to serious injury and even death.
MEMIC policyholders who need further assistance with your Lockout/Tagout program should feel free to contact your Safety Management Specialist at MEMIC or contact MEMIC Loss Control Department to ask for assistance.