MEMIC Safety Blog

Who is the Authorized Employee for Lockout/Tagout?

  Posted by Henry Reynolds

 

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.

 

Operator's Manuals - Instructions Worth Reading

 Posted By Greg LaRochelle

 

These days, due to the global market and cultural diversity, manufacturers produce operator's manuals in several languages that are often confusing. You either find a folded sheet at the bottom of the box that opens into a poster-size layout of seemingly disjointed instructions, or a virtual tome of information that ends up being cast aside as you begin to assemble the product.

 

Of course, just jumping in knee-deep, in a manner of speaking, can lead to confusion, frustration, spare parts, and sometimes, bodily injury.  I recall a number of years ago, finding a product shipped in a container with a VHS tape that offered instructions on properly opening the container.  Think about that one for a moment.

 

That said, though we may have to skip a few pages to continue with the instructions in our native language, it's always prudent to take the time to read the information, especially any safety precautions that are included.  Usually, this section is highlighted and appears at the front of the manual. 

 

I visited a jobsite for one of my abatement contractors recently and was pleased to see the operation and maintenance manual for the newly purchased infrared floor tile lifter in plain sight.  It was obvious the manual had been "flexed" and reviewed prior to the crew using the machine.  Electrical needs and other safety precautions were clearly defined in the manual. 

 

It turns out that temperature and dwell time over a square of tiles was really important for this machine. Otherwise, the vinyl asbestos flooring could overheat to the point of thermal decomposition, rendering noxious airborne by-products.  Not to mention the potential destruction of material. It paid to read these instructions.

 

So, frustrating though they may be, take the time to read the manual – even if you already know how to open the box.

Are you NFPA 70E compliant?

Hartley Webb, a MEMIC Safety Specialist, tells me OSHA is inspecting and citing workplaces—under the General Duty Clause—that are not in compliance with the National Fire Protection Association (NFPA) 70E Standard. 

If your workplace has electricians, mechanics or technicians that work near live electric circuits (exceeding 50 volts to ground),  then they are at risk of electrocution as well as injury from arc blast and arc flash. If a tool or piece of equipment accidentally contacts live electricity, the “welding-style” flash that occurs is very hazardous. A pea-sized piece of copper expands as it vaporizes to a volume of over 36 cubic feet or the equivalent of two, average-sized refrigerators. The heat during this arc event reaches up to 35,000 degrees Fahrenheit (roughly four times the temperature of the Sun’s surface). 

Due to these hazards, the NFPA established procedures for working on or near energized electrical systems. These procedures are titled NFPA 70E – Standard for Electrical Safety in the Workplace. The standard covers how to avoid and protect workers from electrical hazards during maintenance and installation procedures.

In part to keep pace with this national consensus standard, OSHA updated their General Industry Electrical Standard (1910 Subpart S) and published the final rule in the February 14, 2007 Federal Register. An excerpt from the summary follows:

“The Agency has determined that electrical hazards in the workplace pose a significant risk of injury or death to employees, and that the requirements in the revised standard, which draw heavily from the 2000 edition of the National Fire Protection Association's (NFPA) Electrical Safety Requirements for Employee Workplaces (NFPA 70E), and the 2002 edition of the National Electrical Code (NEC), are reasonably necessary to provide protection from these hazards.”

The regulation went into effect on August 17, 2007 and can be viewed at:

• Electrical Standard; Final Rule - 72:7135-7221

In addition, a 2009 update of the NFPA 70E is slated for release this September. The standard is not free and must be purchased. You can buy and view a summary of improved work practices and key changes to the standard on the NFPA website:

• NFPA 70E®: Standard for Electrical Safety in the Workplace®, 2009 Edition

I’m sure this update will raise some questions about electrical work within your organization, but you need to temper potential frustration and look at it as "Are we, or aren't we, in compliance?"