1910.147(c)(4) Energy Control Procedure (878 violations)
Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.
What makes compliance with the “minimum performance requirements for the control of hazardous energy” fall under the umbrella of common violations? To understand this, we need to start by defining the “LOTO” acronym. “lockout” procedures refer to written steps that are taken to bring the machine to a zero energy state. Once a de-energized condition is established, locks are placed on energy isolation devices that enable personnel to maintain control over the hazardous energy.
“Tagout” devices are only allowed as sole means for control of hazardous energy on machines/equipment that was made prior to January 2, 1990, where the equipment is not designed with provision to lock, although they do not provide any sort of control or protection other than warning personnel of the imminent hazard. They are meant to show that the equipment is in a de-energized state and someone is most likely performing maintenance on it.
When combined together, the procedure “lockout/tagout” refers to lockout devices and identification tags being used in conjunction to indicate that a qualified person is safely performing an energy isolated task. When employees follow the LOTO procedures enforced by the companies they work for, they are able to better protect themselves from unexpected re-energization or release of stored energy.
Striving for the minimum requirements of compliance does not lead to achieving minimum risk or maximum productivity. Furthermore, human error plays a vital role in failing to comply with standards. Despite thorough training, documentation and experience, there will always exist that risky margin of a person just simply making a mistake, no matter how many times they’ve performed the task at hand. Today, this risk can be nearly eliminated; however, in order to reach that goal, companies need to look beyond compliance.