Policy Number: II-203
Effective Date: October 26, 2015
Last Reviewed: October 23, 2020
Responsible Dept.: Facility Management Services
Original Issue Date: November 2009
Revision Dates: 11/2010, 11/2011, 11/2012, 11/2013, 8/2014, 10/2015, 10/2020
A signed copy of this policy is available in the President’s Office.
Developed in accordance with the OSHA Control of Hazardous Energy (Lockout/Tagout) Standard, 29 CFR 1910.147 and Electrical, 29 CFR 1910.133
To ensure the safety of employees by establishing appropriate lockout/tagout (LOTO) procedures for equipment that is capable of storing hazardous energy, including but not limited to: electrical, chemical, mechanical, hydraulic, pneumatic, and thermal. Also to ensure compliance with the requirements of Federal 29 CFR 1910.147, Control of Hazardous Energies and Federal 29 CFR 1910.133, Electrical.
Virginia Western shall implement a LOTO program that meets the requirements of this document and any applicable Federal, State or Local laws.
This program shall apply to college employees during servicing and/or maintenance of equipment or machines and at other times when LOTO of energy is required to ensure the safety of those working on or near hazardous energies, if a release of this energy could cause injury to the employee. LOTO is required when the work requires any faculty, staff member or student to place any part of their body into an area where a danger zone exists.
For the purpose of this program, the term “employee” is intended to mean faculty, staff or student.
NOTE: Contractors are required to follow all Federal, State and Local laws and the expectations of the College. Contractors are required to meet the intent of this guideline but shall train and certify their own employees. VWCC and the contractor are required to inform each other of their respective programs.
3. Applicable Forms and Documents
29 CFR 1910.147, Control of Hazardous Energies (Lockout/Tagout)
29 CFR 1910.133, Subpart S, Electrical
ANSI Z244.1-1982, Safety Requirements for the Lockout/Tagout of Energy Sources Proposed ANSI Standard Z244, Control of Hazardous Energy-Lockout/Tagout and Alternative Methods
4. General Requirements
- Assessments shall be performed on each tool/equipment set to identify potential hazardous energies and to document the Energy Control Procedures (ECP). The energy control procedures shall be written in preventive maintenance, modification or other relevant procedures (See Appendix 8.2 Energy Control Procedure Checklist).
- Equipment-specific Energy Control Procedures shall be written for each equipment type that covers:
- Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energies.
- Specific procedural steps for the placement, removal, and transfer of locks and tags and the responsibility for placing them.
- Specific requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO and other energy control measures.
- Energy Control Procedures do not need to be documented for a particular machine or equipment, when all of the following elements exist:
- The machine or equipment has no potential for stored or residual energy, or re-accumulation of stored energy, after shut down that could endanger employees.
- The machine or equipment has a single energy source, which can be readily identified and isolated.
- The isolation and locking out of the energy source will completely de-energize and deactivate the machine or equipment.
- The machine or equipment is isolated from that energy source and locked out during servicing or maintenance.
- A single lockout device will achieve a locked-out condition.
- The lockout device is under the exclusive control of the authorized “employee” performing the servicing or maintenance.
- The servicing or maintenance does not create hazards for other “employees.”
- The employer, in utilizing this exception, has no accidents involving the unexpected activation or re-energization of the equipment during servicing or maintenance.
In utilizing this ECP exception, Virginia Western Community College verifies that our equipment meets all requirements stated in 1 through 8. The college has had no accidents involving the unexpected activation or re-energization of any machine or equipment during service or maintenance.
4.1 Energy Control Procedure (ECP)
- Each Energy Control Procedure (ECP) must be reviewed annually.
- If a change to an ECP happens, the equipment owner must:
- Identify the change and update the ECP.
- Define who will be impacted and/or affected by the change.
- Communicate through any effective means to all Authorized Employees.
- Examples include the following:
- Locks and tags used for Control of Hazardous Energy must be standardized at each location and must not be used for any purpose other than the control of hazardous energy.
- Locks used for LOTO must be RED in color.
- Tags used for LOTO must contain the language: “DANGER-DO NOT OPERATE.”
- Tags used for other applications shall not duplicate LOTO tags in color or verbiage.
- Transfer of LOTO between the outgoing and incoming personnel shall require:
- Personnel to meet at the point of lockout.
- Incoming employee shall apply LOTO devices prior to outgoing employee removing their device.
- No individual shall interfere with another person’s LOTO or try to start any equipment/tools under someone else’s LOTO.
- To remove another person’s LOTO device, removal protocol requires that both a Supervisor, or designated representative, and an Authorized Employee complete the “Abandoned Lock Removal Procedure.” (See Appendix 8.3 Control of Hazardous Energies Abandoned Lock Removal Form).
- Abandoned Lock Removal procedures:
- The FMS Manager identifies the need for lock and tag removal.
- Attempts to contact the person who placed the lock are documented on the Abandoned Lock Removal Form.
- An evaluation of the entire system must be made to ensure that an injury cannot occur before the lock is removed. (Names are documented on the form.)
- If contact cannot be made with the employee who placed the lock, the employee and the FMS Manager must be made aware of the removal and the state of the system before beginning his/her next workday.
- Abandoned Lock Removal procedures:
- Periodic inspections of Authorized Employees shall be conducted annually to ensure compliance with LOTO operation requirements. The inspections shall include a review between the FMS Manager and each authorized employee of the employee s responsibility under the energy control procedure being inspected. The inspection shall be performed by the FMS Manager utilizing the energy control procedure being inspected. (See Appendix 8.4 Periodic Inspection Checklist for Control of Hazardous Energies)
- The inspection shall document:
- The identity of the machine or equipment which the ECP was being utilized.
- The date of the inspection.
- The names and the job title of employees who were included in the inspection.
- The person who performed the inspection.
- The inspector needs to:
- Observe a representative number of such employees while implementing the procedure.
- Each employee shall use locks for which only they possess keys.
- Each person whose work exposes them to a potential danger zone, regardless of length of time, shall apply their own lock and tag to the energy-isolating device before entering that zone.
- If using a lock box, the following steps shall be followed. The Tool Owner, Trades Manager, or person supervising the lockout shall:
- Apply lock and tag to each hazardous energy control point.
- Place the key(s) to the locks in a lock box.
- Affix their lock and tag to the lock box.
- The authorized employee(s) working on the locked out systems shall:
- Affix their lock and tag to the lock box when beginning work.
- Verify that the system(s) they are working on are de-energized and verify the lock is on the correct isolation device.
- Remove their lock and tag when they have completed their work.
- Stop work and inform the person supervising the task of start and stop times and any issues found.
- In all cases, the lockout of energy must be a true isolation, without possible override.
4.2 Alternative Method
- An Exception when LOTO is not required or is impracticable on a machine or piece of equipment is during maintenance activities. This deviation from LOTO procedures must be reviewed and approved. As an example, LOTO may not be required in the instance if it can be demonstrated that an alternative means enable employees to service the machine without being exposed to an unexpected activation of the equipment or release of stored energy.
- A specific alternative method procedure shall be created by FMS and must include the following elements:
- Determine if the task is routine and repetitive.
- Determine why power is required.
- Establish why lockout is impracticable.
- Determine whether or not employees are exposed to hazards.
- Determine if guards are being removed.
- Determine if interlocks are bypassed.
- Identification of the task’s related hazards.
- Qualitative estimation of exposure and severity to determine the level of risk.
- Assessment and evaluation of the risk.
- Identification of control actions selected as the best protective alternative.
- Verification of effectiveness of the selected alternative.
- Documentation of the Risk Assessment Process.
- When an employee is working in an area with potential exposure to electrical energy, they are required to use LOTO. If there is a compelling reason to work on the system energized, the FMS Manger has be informed and there must be a second technician to observe the work. Additionally, the following must be met:
- Dual valve isolation is required for pressurized (>15psi) Hazardous Materials (HM’s). This requires that one valve be locked/tagged out and a second valve to be closed between the source of hazard and the authorized employee. Fora valve to be considered locked/tagged out, you must use a lockable valve, a locking valve cover or a valve cover that prevents the pneumatic line from being reconnected during lockout.
- Lockout/Tagout (LOTO) is not required for equipment that has only one electrical energy source and is capable of being unplugged, provided that the plug is under the direct control and immediate supervision of the employee performing the work for the duration of the task. The plug is under the exclusive control of the employee if it is physically in the possession of the employee, or in arms reach and in line of sight of the employee. This does NOT apply when more than one employee is working on the tool/system.
- Both locks and tags must be used if the system will not physically accept a lock. If a particular piece of equipment does not have a device allowing it to be physically locked out, then only a tag will be used.
- Where a tag cannot be affixed directly to the energy isolating device, the tag shall be located as close as safely possible to the device, in a position that will be immediately obvious to anyone attempting to operate the device.
- Additional means to ensure equivalent to safety lockout are required as necessary. An example would be to remove a valve handle or un-land wires.
- Notify the FMS Manager of any equipment that will not accept a lock so that it can be modified, if possible.
5. Lockout/Tagout (LOTO) Procedures
a. LOTO Preparation
- Obtain the LOTO devices and tags.
- Notify affected employees. Notification shall be by the authorized employee of the application and removal of the lockout devices or tagout devices. Notification shall be given before the controls are applied, and after they are removed from the machine or equipment.
- Read and understand the equipment-specific energy control procedures.
- Locate each energy control point on the equipment.
- Power down the equipment.
- Isolate the equipment from all hazardous energies sources.
b. LOTO Application
- Apply the LOTO device so that it locks the energy-isolating device in the SAFE position. Affix the tag directly to each lock.
- Dissipate, drain, or safely release any stored or residual energy in the system after Lockout.
- Verify that all sources of hazardous energies have been isolated. This should be done by measuring the energy with a meter or gauge and by trying to start the equipment.
- Prior to using the meter/gauge, ensure it is functioning properly. Be sure to return all switches to the SAFE position after testing.
- For electrical, a qualified person shall use test equipment to test the circuit elements and electrical parts of the equipment to which employees will be exposed and shall verify that the circuit elements and equipment parts are de-energized. The test shall also determine if any energized condition exists as a result of inadvertently induced voltage or unrelated voltage back feed even though specific parts of the circuit have been de-energized and resumed to be safe. If the circuit to be tested is over 600 volts, nominal, the test equipment shall be checked for proper operation immediately after the test.
- Perform a Three-Point-Check to ensure your Volt-Meter is working properly:
- Set Voltage Scale to appropriate voltage and test on a known voltage source.
- Check Danger Zone voltage with Meter — Confirm to be Zero.
- Check meter with a known voltage again to confirm proper operation of the meter.
c. LOTO Preparation for Re-Energization
- Inspect the work area to ensure that all nonessential items, tools, etc., have been removed from the danger zone.
- Check that all the guarding and safety controls have been properly replaced.
- Notify “affected employees” and ensure that all personnel are in a safe location before re-energization.
d. LOTO Lock and Tag Removal
- Remove the LOTO locks and tags.
- Re-energize the equipment/system according to start-up procedures.
e. LOTO Lock and Tag Temporary Removal
- Clear equipment of tools and materials.
- Remove LOTO devices.
- Energize and proceed with testing or positioning.
- De-energize all systems and reapply energy control measures in accordance with procedures.
- In situations in which LOTO devices must be temporarily removed from the energy isolating device and the equipment energized to test or position the equipment, also follow the steps above.
f. LOTO Equipment Used
- Do not proceed with the task unless the correct LOTO equipment is available.
- Lockout and Tagout devices have been standardized at each location and must not be utilized for other purposes.
- Durable and uniquely identified locks, with a single key, shall be available for all authorized employees. The key will remain at all times with the individual who places the lock. Locks (as described above) can be available for use by a number of people and stored in a central location. Technicians can take locks to use for LOTO as long as they control the key for the duration of that LOTO. Locks and keys can be returned to a central location afterwards.
- These locks are not to be used for any other purpose (e.g., locking tool, custodial locks, boxes, lockers, chaining equipment, etc.).
h. LOTO Tags
- Durable tags, which will not deteriorate under work conditions, shall be used whenever a lock is placed.
- The tags must contain, at a minimum, the following information:
- Employee’s name
- Warning against hazardous conditions if the machine or equipment is energized.
- Wires, tie wraps, or cords shall be used for securing the tags to the energy control point and must be able to withstand fifty (50) pounds of force.
6. Roles and Responsibilities
- Supervisors/ Managers are tasked with the following responsibilities:
- Ensure that only authorized employees, who are qualified and trained, apply and remove locks and tags. Ensure that employees who are found to have insufficient skills or understanding of LOTO requirements do not perform LOTO and are retrained.
- Implement, manage, and audit personnel for conformance with the Control of Hazardous Energies Program.
- Ensure that all safety equipment is stocked, stored, and maintained in a state of readiness and is available for employee use.
- Ensure that any deficiencies or deviations found in the working procedures are corrected.
- Authorized Employees are tasked with the following responsibilities:
- Shall perform LOTO activities that are in conformance with VWCC’s requirements.
- Retain control of the equipment, system or machinery while a LOTO is in progress and work only under their own lock and tag.
- Maintain LOTO hardware and tags in good condition.
- Complete all training required to be authorized to work with specific equipment, tool(s) or machinery.
7. Training Requirements
- Authorized Employees:
- All authorized employees must initially attend and complete VWCC’s Control of Hazardous Energies Training course.
- Authorized employees will receive equipment-specific training and certification, as applicable.
- Authorized employees must be retrained by completing the Control of Hazardous Energy course if the employee uses blatant disregard of VWCC procedures during periodic inspection.
- Authorized employees shall be coached/receive hands-on training:
- If there is a change in job assignment, a change in machine, equipment or processes that present a new hazard, or there is a change in the energy control procedure.
- The periodic inspection reveals, or whenever there is reason to believe, there are inadequacies in the employee s knowledge or use of the energy control procedure.
- If employee is observed and found to be proficient during the periodic inspection, they are not required to attend the Control of Hazardous Energy course. If employee is not observed during the periodic inspections, they shall attend the Control of Hazardous Energy course to ensure proficiency.