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.

 

Machine Guards and the Cost of Cutting Corners

Henry Reynolds, who works at MEMIC as a safety management consultant, recently told me a story that is a reminder about the importance of machine guarding. And why it’s smart to resist the temptation to cut corners.
 
“I recently had an accident at a company where an employee amputated two fingers and partially amputated two others on his right hand. When I asked the employees’ manager if the accident could have been prevented, the answer was not surprising. Had the operator done the machine set up properly, then yes, this accident could have been prevented. After discussing the proper machine set up procedure, I questioned why the machine wasn’t set up properly, with the machine guard. Again, receiving an unsurprising answer:  'It wasn't feasible.'

Digging deeper, I asked why setting up the machine, with the machine guard on, was not feasible and received the answer I knew was coming. With the machine guard off, set-up was 10 minutes.  With it on, set-up was an hour. The next question was clearly asked too late: Was one hour and saving an employees’ fingers more cost-effective than a shorter set up?

Machine Guarding Standard 29 CFR 1910.211 through 243 specifies areas to be guarded on all types of equipment. It specifies that guards must be affixed to the machines where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.

Here are a few questions to ask when reviewing your machine guards.
o Are all rotating shafts guarded?
o Are employees protected from flying chips from machining?
o Are fingers and arms away from pinch and nip points?
o Are the guards adequate for the machines?
o Have your employees been educated on machine guarding and it's importance?
o Have you done a hazard analysis on each piece of equipment to determine the hazard and what the controls would be?
o After guards are in place, are you inspecting them on a regular basis?
o When a deficiency is found is it corrected immediately?

When all is said and done, we should not hear that machine guarding is not feasible. Where there is a will, there is a way. In tough economic times, you might be tempted to save a few dollars, but cutting corners isn’t going to save money in the long run. It might also be hard to challenge your employees, or your managers, to change their way of thinking about machine guarding.

 The old “Seven Steps of Stagnation” are worth reviewing when educating your employees and/or managers on the many reasons for proper machine guarding. The Seven Steps of Stagnation are:

1. We've never done it that way.  
2. We're not ready for that.
3. We're doing alright without it.  
4. We tried that once before.
5. It costs too much.
6. That's not our responsibility.
7. It just won't work.

If you need further assistance with machine guarding issues and inspections on equipment to verify proper guarding you may contact your safety management consultant. You can also check out these resources on machine guarding:

OSHA Concepts and Techniques of Machine Safeguarding

OSHA "e-Tool" Machine Guarding

Lab Safety's EZ Fact, General OSHA Machine Guarding Requirements

A great resource for aiding in machine guarding solutions is Rockford Systems, Inc. I recommend them to many of my clients in need of machine guard solutions. Another great resource for machine guard solutions is contacting the manufacturer directly. More times than not the manufacturer will offer machine guards or be able to put you in touch with the company that makes the specific guards for your machine. Feel free to let us know of your favorite machine guarding resources.”

Protection through Inspection

“The right tool for the job” is an old saying. And it turns out it’s a good safety saying too. Although it may conjure up a construction or manufacturing setting, there isn’t a workplace where it doesn’t ring true. One example of the wrong tool for the job is an office worker who uses a chair to reach the top shelf. Another is a healthcare worker who lifts a patient without using a mechanical aid because "it's in the other wing." No matter the setting, if the proper tool is not used when needed, you're in the high risk zone right out of the gate.

Even if you have the right tool, there's a second consideration that is just as important. Is the tool in serviceable condition? If it's the right tool and it's in good shape, I predict you’ll have a great day at work. If it's the right tool and it’s defective, you may be worse off using it. This brings us to the matter of proper inspection.

I obviously don't have enough space in this blog to get into specifics. Too many tools, too many workplaces. But there is one universal resource that can dial up the proper inspection process for whatever tool or equipment you’re using and it’s called the manufacturer’s information or manual. Not only will it give you the "what" but also the "how" and the "how often."

But one inherent flaw with this booklet is that it's typically the first thing to get tossed once the item is unpacked. If this is the situation you find yourself in, then head to the manufacturer’s website or contact the vendor who made the sale.

Two other items to consider on this topic are documentation and removal from service.

Documentation is another area where you need to keep it simple. Do you need to document the inspection of a 40-foot power cord every time you use it? Probably not realistic. However, if you’re doing an annual required inspection of that patient lifting device I mentioned earlier, then you’d certainly want that on file. Again, your manufacturer’s information will likely provide some direction.

The last thing in this overview of inspections involves taking something out of service. I personally have done several incident investigations where someone got hurt because the tool was defective and a coworker knew about it before the accident. Somehow the defective item needs to be taken out of service. There are many ways to do this including:

• put a visible tag or other indicator on it so others know it's broken, 
• have a dedicated area to bring defective items to, and 
• render it inoperable if it cannot be repaired and put it in the trash.