OT- personal safety for everyone

Everyone,

We just finished a LOTO class for machinery and we were asked how many times we had to lock out machinery.

My counterpart said maybe 1 time in his career and I can also say the same.
Sure, we turn the power off to do wiring, but what about trouble shooting?

Most of us on the forum are in the unique position that we work with machinery while its powered on and running.
We goto the machine and look in the code to see what is wrong. Most of the time its a prox, limit switch, motor fuse blown, or something like that.

for example, our machines are 500 ft long or longer and have several floors of space used.
When I am on call I get calls all hours of the night and have to remote into the plant to see what's wrong. I am in contact with maintenance while doing the online edits if required.

My point is, do we think about others working with the machine we are working on? Are we in contact with maintenance while we are doing online edits and make sure everyone is clear before testing those edits?

Please take the time to make sure everyone is clear before bypassing sensors, forcing outputs, starting machinery in control rooms and the machinery is several hundred feet away.

Stored energy in hydraulic hoses, pneumatic air lines and tanks, vfd's with large capacitors, conveyor systems that have hung up, and other devices can cause injury or even worse.

Something to think about as we had an employee loose a finger recently due
a conveyor being hung.

Not trying to make anyone mad or offend anyone, just trying to say safety first, for all involved.

james

I frequently work around similar sized equipment but the big 3 automotive are very strict on safety design and following procedures. Just touching up a robot or photo-eye is a lengthy ordeal. If you're caught not following them its an immediate escort out of the plant.

If you turn the power off to do wiring, aren't you locking it out? Over the past few years I've tried to break the habit of taking it for granted that because I turned the disconnect off, and I am working near it, and nobody else is that it is 'safe'.

LOTO is only relevant if your work requires you to isolate energy to complete the work. For troubleshooting, you can't LOTO. A "qualified" person can work in a panel w/proper PPE. But if you are going to add components to a control panel it should be properly shutdown, locked out and verified to be de-energized before working in the panel. Does this always happen? Of course not. I've been in many facilities and electrical safety has rarely had much enforcement. I've only seen it in facilities where they are highly regulated and require a paper trail for most everything. Policy & procedures are an audit item as such they are more visible. Even if a facility has a safety program in place, and safety officer, my experience is that they hammer on fall protection, fire watch and scissor lift usage, mechanical equipment and completely ignore anything related to electrical.

I've seen plenty of electricians/engineers working in control panels w/o the proper PPE (including me). Granted I tend to only mess in panels that are 24VDC - 120VAC. Anything with 480VAC I may open the door and inspect an installation or mess with VFD parameters. Even still, contract electricians in short-sleeves, no gloves and working in live panels is pretty common in my world.

In 10 years of doing this work I have never seen anyone working with 100% proper PPE. On the most basic level it should be cotton clothing, full sleeves, hard hat w/faceshield, rubber gloves and leathers when electrical energy is present. I've never seen it. Getting into NFPA, anything above 50 volts is a 'shock' hazard, but how many 120VAC control panels are being worked in on daily basis by people w/o rubber gloves, leathers and face shield?

Arch Flash has changed the game a little bit, but for low voltage panels w/finger safe terminations most hazards are pretty well engineered out, always powering down these panels simply isn't realistic in most facilities. I'm not endorsing working in a 'non-safe' manner, simply saying I've yet to see a true LOTO procedure where everything is locked out, verified by someone w/proper PPE prior to working w/o PPE.

To the points of programming, I am always aware of what I'm changing, what is running/not running, people that are present, what the expected impacts are, what the risks could arise. I'd say that I try to be "situationally aware" best I can. But certainly can't have eye's and ears everywhere.

Paully's5.0 said:

LOTO is only relevant if your work requires you to isolate energy to complete the work. For troubleshooting, you can't LOTO. A "qualified" person can work in a panel w/proper PPE. But if you are going to add components to a control panel it should be properly shutdown, locked out and verified to be de-energized before working in the panel. Does this always happen? Of course not. I've been in many facilities and electrical safety has rarely had much enforcement. I've only seen it in facilities where they are highly regulated and require a paper trail for most everything. Policy & procedures are an audit item as such they are more visible. Even if a facility has a safety program in place, and safety officer, my experience is that they hammer on fall protection, fire watch and scissor lift usage, mechanical equipment and completely ignore anything related to electrical.

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Since I do a little automation and I'm my site's safety/security/environmental guy, I'll chime in here. LOTO applies if unexpected energization, startup, or release of stored energy can result in injury (29 CFR 1910.147(a)(1)(i)). It also applies if the work you're doing requires you to remove or bypass a guard or other safety device ((a)(2)(ii)(A)).

There are exceptions to LOTO when you go into a machine for stuff that's "routine, repetitive, and integral to operation" while you're in production, but that still requires you to have alternate measures in place that provide effective protection. We actually have a pre-defined list of the allowed exceptions that meet the "routine/repetitive/integral" guidelines and that we can provide alternate effective protection for. Otherwise, LOTO.

If an operator or mechanic in my plant needs to run a machine with a guard bypassed for troubleshooting, they are not allowed to do anything that puts any part of their body past the imaginary plane where the guard was. I've walked people out the door for violating that. They can put a tool past the "safety plane", but if they need to reach in, they have to stop and LOTO. I'll gladly take the OEE hit for the extra time it takes.

Failure to LOTO is basically zero-tolerance in my plant - about the only time you would catch a break is if it's a management system failure - you followed the procedure I gave you, but the procedure was inadequate or ambiguous.

The way I understand it is such. There are several levels of controls for "Risk Management".
"Engineering Controls" - are items such as guards, light curtains, motion sensors. They are engineered devices that manage the risk of injury.

"Administrative Controls" - are policy/procedures put in place to manage risk, such as LOTO, Confined Space, Hot-work Permits, but require the workman to "do the right thing" in order to manage the risk.

"Personal Protective Equipment"- Equipment utilized as a last resort to manage effects of hazards.

If I do anything to bypass "Engineering Controls" to operate a machine that then causes harm to an individual, I open myself to immediate termination, and likely a lawsuit, as I will have been directly involved. This might be forcing an input to over-ride a safety mechanism in place. I have done this, but I also communicate rigorously with plant personnel what is about to happen. I also will not do it remotely. I have to be on premises.
LOTO- Is not meant to be "easy" to comply with, but I use it whenever I do not have direct control of the energy isolation means. If I'm working directly in a panel, for troubleshooting, LOTO is not required. However....NFPA 70E has other limitations to working around exposed energized parts, which may include have not FR rated clothing/PPE, but ARC rated clothing/PPE and gloves and possibly a face shield.

I was involved in a very lengthy and in depth arc flash assessment of our facility, and subsequent overcurrent/arc coordination study.

In a processing business with a global footprint, we take personal safety very seriously!

I agree with what you have said, 100%

I will use myself as an example.

In almost off of my jobs, I have had to work on equipment as it's running production (commissioning the system, doing a runoff in most cases). I get a call stating something is wrong and I then have to watch the machine, look at the program, look at the operation, and other things. When it stops for unknown reasons, I stop the machine using the controls, we open the safety door / remove the guard and keep clear just to see where the problem is. Safety procedures are met as far as they can be taken since I will be creating a more dangerous situation by removing the air or hydraulics.

WE don't need to develop a false sense of security just because we are the controls guys and the loto rule doesn't apply to us (as least in my career. I have always had maintenance there with me as I work with them, watching out for me and I watch out for them).

I have developed the habit of looking out for production workers, maintenance, management, and supervisors and knowing where my limitations are as far as control of the machine.

You must notify everyone when a programming change is being made and to be clear of the machine(even safety guarding) just in case.

We had an incident here in which someone got that false sense of security and got hurt, not badly in this case.

My post is to help alert everyone, engineers, maintenance, and controls people to take the time to see who is doing what when working on a machine.

Please take a few extra seconds to make sure everyone is clear before doing anything, see what state the machine is in, and the possible dangers in regards to everyone. Those few seconds would have spared the person at our plant a lot of grief.

I do apologize for being long winded and do not wish to offend anyone, but let's not forget that the controls and maintenance people most of the time come to a machine when there is a problem and not knowing what the problem is, what the next step in the machine cycle is, or if the machine is still in the automatic cycle.

james

I actually always follow on-site procedures. So I do LOTO on a regular basis.

There are situations where I would run a machine with removed guards or other things that in a regular production situation would be considered a severe safety violation.

But this is always done with authorization and workplace safety in mind and normally the area would be off-limits to unauthorized personnel during the procedure.

Still, safety is always a good thing to be reminded of.

Process industries often span large areas and some things you can do on a machine is impossible in a process industry. So safety can be a tricky thing.

James Mcquade said:

WE don't need to develop a false sense of security just because we are the controls guys and the loto rule doesn't apply to us (as least in my career. I have always had maintenance there with me as I work with them, watching out for me and I watch out for them).

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That's the thing - strictly speaking, LOTO under 1910.147 actually applies to electricians, controls engineers, etc. once you move from the electrical enclosure into the equipment being powered/controlled. The last two employees my site let go for LOTO violations were actually supervisors. One of them even said they thought LOTO didn't apply in the situation they were in when I was investigating the incident.

Since I'm the guy ultimately responsible for workplace safety at my plant, I tend to err on the safe side with LOTO, because that would send a bad message if anyone saw me doing anything less. A couple weeks ago, I was doing some work testing a vision system on one of our lines. The facility was completely empty except for the guy manning the boilers/ammonia cooling system, sitting in his office 300' and 2 floors away. Because I had to remove a fixed plexiglass window on a machine, I went ahead and LOTO'd the equipment.

bdjohns1 said:

Failure to LOTO is basically zero-tolerance in my plant - about the only time you would catch a break is if it's a management system failure - you followed the procedure I gave you, but the procedure was inadequate or ambiguous.

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If you have a zero tolerance for LOTO failure, then shouldn't the person who failed to properly verify the procedure prior to issuing it be walked out?

Will.

Pete.S. said:

Process industries often span large areas and some things you can do on a machine is impossible in a process industry. So safety can be a tricky thing.

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Agreed. The process world is like a whole different ballgame. In machine safety, you're generally trying to prevent someone from losing an arm. In Process safety, you're trying to prevent an oil refinery from exploding and killng everyone.

Kicks things up a notch.

bdjohns1,

I agree, but how do you debug a machine that has stopped production and you turn the power off to the plc, remove air and hydraulics so you can remove guards to look at the machine itself? You can't.

You can make conditions more hazardous by removing power, air, hydraulics.
Each situation is different.

james

willxfmr said:

If you have a zero tolerance for LOTO failure, then shouldn't the person who failed to properly verify the procedure prior to issuing it be walked out?

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I was simplifying a bit - the failure has to be willful and put an employee in "imminent danger" of harm - ie, the procedure caused the equipment to not actually be isolated, because you would not have been able to verify the machine was in a safe state, which means that you didn't verify the procedure you wrote, and the person who audited/verified the prodeure on an annual basis for OSHA compliance pencil-whipped the audit. That's where the zero-tolerance bit comes in. (We also apply that to other high-risk situations - not wearing fall protection when required, non-qualified employees in energized electrical panels, not wearing the right PPE when handling high-strength sanitation chemicals, etc. Every employee signs off on that list of things physically when they're hired, and they have to re-acknowledge it at minimum annually.)

Here's an example where I didn't terminate an employee - I was on the floor and walking by an employee doing cleaning on a casepacker. I saw that he had his locks on, but the 1/4-turn handle on air line to the machine itself was locked in the on position, not the off position. Apparently, the valve handle at some point broken and was replaced with one that had a hole for a padlock in the on and off position. He did have energy to the machine isolated, and was able to verify that the machine was locked in a safe state to me - because when he locked out power, the safety circuit for the air supply dumped the air just downstream of the valve that is the documented lockout point.

Because he had achieved effective isolation and verified it, he wasn't placing himself or anyone else in imminent danger of injury. He just got some coaching as a reminder of which way is on/off, and I grabbed a mechanic to cut off the loop that allowed the valve to be locked open.

Another example - OSHA says that lockout devices have to among other things, identify who has a lock on the device. We buy laser-engraved locks from Master once an employee completes their authorized user training. Until you get those locks, we have generic padlocks. You have to affix a tag to that lock with your name on it. If an employee fails to do that, they may receive discipline and re-training. But, if they applied the lock correctly and maintained control of the key, they didn't place themselves in imminent danger. That wouldn't result in termination, unless they did it enough times that they exhausted our progressive discipline program.

Good discussion here.

James Mcquade said:

bdjohns1,

I agree, but how do you debug a machine that has stopped production and you turn the power off to the plc, remove air and hydraulics so you can remove guards to look at the machine itself? You can't.

You can make conditions more hazardous by removing power, air, hydraulics.
Each situation is different.

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You're absolutely right - we don't want to create new hazards either. That's why in those rare cases when we do get into a situation where machine guarding needs to be removed, it needs to be approved by me, and we need to plan out what the safeguards are going to be - basically, we're trading down from engineering controls to administrative controls at that point. It doesn't have to be a very convoluted and drawn-out process, but a standard process should exist.

Last month, one of our line mechanics wanted to use our high speed camera to troubleshoot a problem he was having on a filler, and he needed to have guarding removed so that he could get the camera into the right position in the machine. He paged me to the floor to get approval, and we got through the entire process to get troubleshooting started right there in under 10 minutes.

1. Notify all of the affected employees in the area.
2. LOTO the equipment to remove the guards and get the camera installed.
3. Install a bypass for the safety switch on the door that was removed (those are controlled to prevent extra actuators from making their way onto the floor)
4. Put up cones / caution tape to keep people clear of the affected area where the guards were removed.
5. Run the equipment. Any situation where a person would be putting any part of their body past the guard door opening would again require LOTO.
6. After completion of the high-speed footage capture, LOTO, remove the camera, remove the bypass device, re-install the guards, remove LOTO, and return the machine to service.

One thing we've tried to do in concession to the fact that LOTO can be a pain in the *** is to try and make it as convenient as possible and as fast as possible so people aren't looking for excuses not to LOTO. On our newest lines, we've got the power to all of the machine's servos and VFDs partitioned from the control circuits. For routine stuff (cleaning inside the machine, minor servicing), the operators can lock that disconnect, lock out the air, and they're set. The 24V control circuits, PLC, HMI, etc. can stay powered. When they unlock, the only delay is waiting for drives to reboot, which is just a few seconds versus waiting a minute for the HMI to boot. But, if an electrician were replacing a servo controller, they'd still have to dump power at the main enclosure.

Even on older equipment, we've at least moved the disconnects to a convenient location so you're not going to 4 or 5 places to lockout a line. Ideally, they're within a few steps of where the operator is normally stationed, and we train every employee to the "authorized user" standard for LOTO, so they don't have to track down someone to LOTO.

100% in agreement.

The point I wanted to make was to have the forum members think about safety, for them, operators and maintenance. Don't assume anything.

And I do believe that this discussion has done a good job and hopefully
will make everyone a little wiser.

james

James Mcquade said:

100% in agreement.

The point I wanted to make was to have the forum members think about safety, for them, operators and maintenance. Don't assume anything.

And I do believe that this discussion has done a good job and hopefully
will make everyone a little wiser.

james

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Agreed. I took over ownership of safety at my plant last summer. It's encouraging to me that in that time, I'm seeing more employees coming to me with questions/comments on how/where to lock out equipment safely in complicated scenarios (mixproof valve manifolds), versus questions/gripes about whether or not they have to lock stuff out, trying to get more exceptions, etc. That means they're stopping to think a little bit more, and stopping before acting to think about safety is pretty much always a good thing, whether it's your own safety or the people around you.

-Ben