The Alternative Universe of Lockout/Tagout

On the surface, at least, machine lockout/tagout (LOTO) appears simple: Identify and isolate energy sources, lock and tag, and perform the procedure that needs to get done.

Simple, right? Wrong.

When energy is required to complete machine diagnostics or set-up work, or when a minor maintenance job is going to throw production hours behind schedule, LOTO becomes something far more complex than a textbook explanation.

Once you understand its intricacies, it is understandable why LOTO, as outlined in OSHA standard 29 CFR 1910.147 ”The Control of Hazardous Energy (Lockout/Tagout), has become an everyday struggle for many safety personnel. And why LOTO ranks among OSHA’s top ten violations, year after year. It is also understandable why industry is fast embracing the concept of “Alternative Measures”.

OSHA 29 CFR 1910.147 requires employees to remove power sources to a machine that could otherwise result in personal injury if energy were unintentionally released during maintenance or service. It clearly states facilities are responsible for establishing a written program covering how required safety measures will be applied. This includes provisions for developing machine-specific energy control procedures, training authorized workers to protect themselves with lockout/tagout, and for periodic inspections of the adequacy of the written procedures, along with the performance of personnel applying them.

As comprehensive as LOTO may be, it can be very time-intensive, often requiring longer than is required to finish the actual maintenance task on the machine. Production comes to a halt, resulting in the day’s production numbers potentially being missed. This becomes even more frustrating when the maintenance task is one that must be implemented several times a day. Loss of time and profits create a strong incentive to bypass LOTO to carry out repetitive machine tasks. However, it still violates OSHA requirements and puts workers in serious danger.

Thankfully, OSHA 29 CFR 1910.147 also outlines “Alternative Protection Measure” (APM) procedures that can result in increased efficiency without compromising the safety of the operation. This exception is also referred to as the “minor servicing exception”. Designed for machine tasks that demand frequent repetitive access, i.e., clearing a jam on a conveyor or a minor tool change, Alternative Measures do not require that power sources be completely cut off. Examples of Alternative Methods technology may include key-controlled locks, control switches, interlocked guards, remote devices and disconnects. It can also mean locking out just a section of a piece of equipment, rather than the entire machine.

The newest ANSI standard, ANSI/ASSE Z244.1 (2016) The Control of Hazardous Energy – Lockout, Tagout and Alternative Methods, agrees with OSHA in that workers should be protected from injury due to unexpected equipment startup or release of potentially hazardous energy. However, the ANSI committee did not try to align fully with every historic OSHA compliance requirement. Instead, the new standard gives expanded guidance beyond OSHA’s regulatory limitation to tasks that are “routine, repetitive and integral to production operations”.

ANSI makes it very clear that LOTO shall be used unless the user can demonstrate that a well-established alternative method will provide effective protection. In situations where the task is not well understood or risk assessed, lockout shall be the default protective measure applied to control machinery or processes. Section 8.2.1 of ANSI/ASSE Z244.1 (2016) specifies that alternative methods shall only be used after hazards have been assessed and documented through the application of a Practicability (or Justification) Study to determine that the techniques used will result in a negligible risk or no risk for sudden start up. Following the Hierarchy of Control model, ANSI/ASSE Z244.1 (2016) provides detailed guidance on if, when, and how a range of alternative control methods can be applied to result in equal or improved protection for people performing specific tasks. In addition, alternative risk reduction methodology is covered in detail specific to a number of new technologies including the Packaging, Pharmaceutical, Plastics, Printing, and Steel Industries; Semiconductor and Robotic Applications and others challenged by the current regulatory limitations.

Since the two standards are somewhat conflicting it is best to review ANSI first to help identify discrepancies that may not meet federal minimum regulations.

At this point, it would be appropriate to underscore that LOTO provides the greatest level of protection and, whenever possible, it should be utilized to protect employees from hazardous energy. In other words, inconvenience alone is not an acceptable excuse to use alternative measures. In addition, CFR 1910.147 clearly states that an allowable alternative measure must provide the same or greater level of protection as LOTO. Otherwise, it is considered noncompliant and therefore insufficient to replace LOTO.

By using standard safety-rated devices, such as interlock gates and e-stop buttons, a plant manager can achieve safe, reliable machine access that replaces standard LOTO procedures without violating OSHA requirements. Implementing alternative procedures to ensure equivalent protection for specific tasks can enhance productivity without endangering employees. But those procedures — and their benefits — come with strings attached, requiring a thorough understanding of the latest OSHA and ANSI standards.

Detect-A-Finger® Prevents Welding and Riveting Injuries

According to the Bureau of Labor Statistics, more than 5,000 American manufacturing workers suffer injuries involving amputation or limb loss every single year. In all, amputations rank in OSHA’s top three serious workplace injuries. The Detect-A-Finger® drop-probe device is designed to prevent a riveter, welder or other small machine from cycling if it encounters fingers in the point-of-operation area, therefore preventing contact between the operator and dangerous moving parts.

Simplicity is the key to Detect-A-Finger’s success. Whenever an operator initiates a machine cycle, typically through an electric foot switch, the Detect-A-Finger sensing probe is automatically released, ensuring that safeguarding can not be deactivated or overlooked by the operator. If the probe detects anything more than the material thickness, it halts the machine from cycling. However, if an operator’s fingers or hands have not entered the point-of-operation area, the sensing probe will drop into its preset position, and the Detect-A-Finger’s control unit will allow the machine to cycle to maintain ongoing machine productivity and performance.

With its compact design, Detect-A-Finger easily mounts on most machines, regardless of brand, providing fabricators with an invaluable way to enhance both safety and productivity. Depending on space and preference, the drop probe assembly can be mounted on either the left or right side of a machine, while the head and control unit are normally mounted on the machine frame or custom-fabricated brackets. The aluminum probe rod is shaped to fit around the tooling, allowing parts to be formed safely at high speed to achieve maximum output.

Protection For Most Machinery
Accidents occur on all types of manufacturing equipment, which is why Rockford Systems offers its proven Detect-A-Finger system to safeguard virtually every machine found on a plant floor.

The RKC-000 Detect-A-Finger model is for smaller machines, including riveters, eye letters, stalkers, staplers, crimpers, and fastening and assembly machines. Available now online for $868.00 (USD), this version is ideal for retrofitting machines to meet new safety standards.

The RKC-500 Detect-A-Finger model is exclusively for welders. The unique design of its sensing probe module allows it to be attached to a welder arm, whether it is fixed or moving. Depending on the type of welder, a single-stage or a two-stage foot switch may be required. It may also be applied to mechanical foot pedal-type welders, although the mechanical pedal must be removed and replaced with an air cylinder. The RKC-500 is available for $1,053.00 (USD).

The DAF-100 Detect-A Finger model is the premium version for both riveters and welders. Featuring an adjustable stroke up to four-inches, it comes with the control box, drop-probe assembly, aluminum sensing probes, and other necessary components. The DAF-100 is available for $1,998.00 (USD).

All Rockford Systems Detect-A-Finger versions are designed for compliance with OSHA 29 CFR, Subpart 0, 1910.212 general requirements for all machines.