The OSHA standard, 29 CFR 1910.147, is the place to go if you want to find the final rule on controlling hazardous energy. This rule is more commonly known as the lockout/tagout rule, or the LOTO rule.
The opening sentence of the LOTO standard reads: “This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy.”
You may be thinking, “We don’t do any maintenance of equipment in our normal, day-to-day routine, except for a little station and apparatus maintenance.” Right you are, but there are many incidents that can expose us to a source of hazardous energy. Hazardous energy can be found in industrial buildings, pumps, lift stations and elevators, to name a few.
Picture this: You respond to a report of a person trapped in an elevator. You arrive and send one of your crew to the elevator room to shut off the breaker, which he does. Upon his return, you and the crew head to the reported floor to find the elevator stuck, with about 18 inches of the car door still visible. You use your elevator keys to open the door and start the process of removing people trapped inside the car. Meanwhile, a building worker goes into the elevator room and notices the breaker turned off. He innocently flips the switch, and you instantly become faced with a live elevator and no quick way to disconnect the power without running back to the basement and throwing the switch.
OSHA expects that in the course of our work, we as first responders will control hazardous energy and not put our crew and the people we serve at any additional risk. LOTO is the means by which we control some sources of hazardous energy.
What’s LOTO?
LOTO is a method of controlling hazardous energy that involves using a system of locks and tags to prevent the equipment from being re-energized before those exposed to the equipment are clear of it. It involves placing equipment in a zero mechanical state or, to put it simply, shutting it off.
Padlocks are physically placed on switches, valves, breakers or any other source of energy in such a way that no one can activate the energy source until the locks are removed. It’s important to note that the LOTO system is a one key/one lock system. That means that there are no spare keys to the LOTO locks hidden on the BC rig somewhere.
And who do you think holds the key? The person(s) who will be exposed to the hazards. If that person somehow loses the key, they must use a set of bolt cutters to cut off the lock themselves (with a witness, of course).
If multiple personnel will be exposed to the hazards, then each person needs to apply a lock to the switch. If there are one or two switches and a couple valves, then each point of hazardous energy should be controlled with a lock, which means there should be a lock for each exposed rescuer. You must be thinking, “We’d need 50 locks to pull that off!” Later, I’ll discuss a system to minimize the number of locks and to speed up the whole operation.
Going LOTO
Although it’s easy to get tunnel vision and forget to lock out energy sources in the face of competing priorities, when responding to any call that involves machinery, the company officer must be thinking about LOTO from the beginning. The best way to accomplish LOTO is to assign one crewmember to the LOTO function and then have them report back with the keys when they’re done. Tip: Be sure to have a site worker assist the LOTO person, as the workers will know exactly where to disable the right equipment.
In the meantime, other crewmembers can size up the scene, gathering other needed rescue equipment and getting a plan together. When the LOTO person returns with the keys, they just hand them to the crew that’s going into the exposed area, and that’s it. You are locked out and tagged out.
Remote Control
The above procedure works well if you have only one person going into the exposed area. But what if a crew of four personnel is entering the hazardous area? Can you really expect the LOTO person to hang four locks on each energy source? That can add up to a lot of locks. One alternative is to station a crewmember at each energy source to make sure it’s not turned back on, but that’s not a great use of manpower, especially if it’s limited.
To solve this issue, the fire service has adopted the “remote lockbox” procedure from industry. The LOTO person goes to all the energy sources (with a site rep) and applies one lock to each. Tip: To ensure the LOTO process is successful, try to start the locked out equipment after applying the locks (if/when safe to do so).
The LOTO person then brings all the keys back to the incident area and drops them into a red group lockbox.
Next, the personnel entering the hazardous area apply one personal lock (as I mentioned earlier) each to the remote box, effectively securing all the keys to the lockouts. No lockouts can be unlocked until all the rescuers have removed their personal locks. Remember: All personal locks should include the person’s name and their department name for easy identification, as well as a wrist loop for easy key storage.
Usually, the entry team applies their locks just prior to entering the space, and the box stays at the entry point for the duration of the operation. The keys to the original lockout locks must remain in the possession of the LOTO person until the entry team is ready to lock out. The keys cannot sit unsupervised in the corner while waiting to be secured in the group lock box.
Industrial Sites
If you have a large industrial installation in your area, you may get called in for a rescue that occurs during the installation’s planned maintenance project. During these projects (called turnarounds), the plant will hire hundreds and sometimes thousands of contract workers to complete the job. In these situations, the energy sources are usually locked out, so you’ll find a large lockout board in the operator’s area.
When gathering information for the rescue, immediately ask the site rep about the LOTO location. It could be far away from the actual rescue site.
You may also encounter some sort of in-house emergency response team. Preplan with this team whenever possible to optimize your teams’ rescue capabilities.
LOTO Training
All personnel must be trained in the application of and the need for the LOTO method. Training should include the following:
- A review of OSHA standard 29 CFR 1910.147;
- Use and application of all LOTO equipment carried on the apparatus;
- A practice session using a LOTO prop or actual LOTO equipment; and
- Documentation of the training.
Important: Any time a new piece of equipment is added or a change in procedure is made, training must take place. I also suggest adding an annual LOTO refresher to your training schedule as this is one of those skills that doesn’t get used often, but needs to be done right when the time comes.
Conclusion
LOTO is an important safety function in any incident involving machinery or hazardous sources of energy. It may be as simple as taking the keys out of a backhoe or disconnecting a vehicle battery. But it may also involve a complex process of shutting off breakers and valves, and then using a series of padlocks and various devices to ensure that these sources of energy cannot be activated while personnel are working in the hazard area.
Recall the incident I described earlier involving the person trapped in an elevator. If the original responder had simply applied a lock to the elevator breaker and took the key with him/her back to the incident area, there would be no chance of the elevator being turned back on.
The bottom line: Make sure everyone goes home safe. Practice and use LOTO.
