The View from 30 Feet: Lockout/Tagout

by Jen Clark

Plastics Business

Business gurus often talk about the view from 30,000 feet – the big picture that provides a look at overall operations. Perhaps, however, the focus should be on the view from 30 feet – a close-up of specific processes and procedures that make an impact now.

Any manager whose company has ever been the target of an Occupational Safety and Health Administration (OSHA) investigation knows the process can be pretty stressful. Most inspections are conducted without prior notice, but there are a few instances in which OSHA may give notice to the employer – normally less than 24 hours, however.

Among its standards, OSHA mandates employers must take steps to prevent accidents associated with hazardous energy in the workplace. OSHA's standard on the Control of Hazardous Energy, found in CFR 1910.147, commonly is referred to as lockout/tagout. It is meant to prevent the unexpected startup of machines and equipment – or release of stored energy – to prevent workplace injuries during service and maintenance operations. For the plastics industry, OSHA says this practice also should be performed on presses during mold changes and when clearing jams.

During an inspection at a MAPP-member company, OSHA insisted that lockout/tagout be used during changeovers. However, as an industry, it doesn't make sense to lock out the power when changing out a color or a mold because adjustments need to be made on the fly. The company reached out to the MAPP community for guidance on finding an alternative to a full shut-down – a satisfactory solution that would keep everyone safe.

Adjustments were put in place that satisfied OSHA's requirements. "The solution that we used was really simple," explained the MAPP member. "The door used to get into a mold runs on a rail. What we did was drill a hole in the rail and put a lockout/tagout station right there. The door can't slide closed, so the photo eye can't be tripped and the machine can't decide that it's ready to run. It's simple, it's effective and it passed. It was a very logical sequence," according to the member. In addition, OSHA required that the procedure and training for such be documented and kept on file for review.

"Any time a plastic processor's employee must clear a jam, perform maintenance or service powered equipment, they must follow lockout/tagout procedures," said Dianne Grote Adams, MS, CIH, CSP, CPEA and president/CEO of Safex, who recently conducted a webinar on lockout/tagout for MAPP members. The procedure isn't needed only "when the equipment is powered with a plug, and the plug can stay in visual line and (within) hands reach of the individual doing the work."

OSHA requires companies to use appropriate equipment for lockout/tagout. The locks and tags only should be used for lockout/tagout; must be durable, standardized, substantial and identifiable; keys must not be shared; and multiple locks must be used if more than one person is working on an energy source. In addition, each person working on a piece of equipment must apply their own personal lock to the lockout device. Assuming a piece of equipment only has one electrical source is a mistake, Grote said, because equipment often has two or more electrical sources.

Exceptions to the lockout/tagout rule, as noted by Safex, come during minor tool changes and adjustments during normal production, when work is routine, repetitive and integral for production and when alternate protective measures are used.