Standard lockout procedures typically deal with the servicing of machinery by individual workers. But sometimes one person isn’t enough to service a piece of machinery or equipment. It takes a group effort to get the job done. Of course, more workers means more risk. That’s why OSHA requires there to be additional procedures in place when the machinery is being serviced by a group of workers. Here’s a look at the OSHA group lockout rules.
What the OSHA Standard Requires
The OSHA Control of Hazardous Energy (Lockout/tagout) Standard requires the use of lockout procedures any time a worker services certain pieces of equipment or machinery (which, for simplicity’s sake, we’ll refer to collectively as “machinery”) in your facility or workplace. Employers must determine which pieces of machinery have the potential for unexpected energization, start-up or release of stored energy. They must then create procedures to ensure that sources of power to that machinery are locked out when workers are servicing it.
The OSHA standard also allows you to“tag out” equipment instead of locking it out under certain circumstances.This involves affixing a prominent warning device, such as a tag, to the machinery to let everybody know that the machine is being serviced and shouldn’t be started up or operated unless and until the tag has been removed.
When groups are involved in the servicing of the machinery, additional requirements kick in. The underlying purpose of the group lockout rules is to ensure that each member of the team or group has the same level of protection that an individual would receive if the servicing involved only one person. In other words, a group lockout must be as safe as an individual lockout.
Group lockouts involve not just more but different kinds of dangers from individual lockouts. For example, suppose three workers are servicing a compactor. There’s a chance that one of the workers will place his arm in the machine when he’s out of the sight of the other two and that one of those other two workers will activate the compactor at precisely that moment. The group lockout requirements are designed to account for these and other unique dangers associated with group lockouts.
How to Comply with Group Lockout Rules
To protect your workers’ safety and ensure compliance with the OSHA requirements you must make sure that your lockout procedures specifically address the servicing of machinery by groups or teams of workers. A good approach to creating group lockout procedures is to use your company’s basic lockout procedure as a foundation on which to overlay a set of additional procedures to follow when servicing is done by a group.
How to Create a Group Lockout Procedures Memo
It’s also advisable to create a memo describing your group lockout procedures and distribute a copy to each affected worker, including those authorized to perform servicing in groups. Click here for a Model Memo you can adapt. Although it needs to be tailored to meet the circumstances, equipment and procedures applied at your particular workplace, like the Model Memo, yours should:
1. Explain When Procedures Are to Be Used
Tell workers that they must follow the group lockout procedures set out in your Memo whenever they service a piece of machinery in a group or team.
2. Designate Worker Responsible for Implementation
Designate one worker from the service group to be in charge of making sure that each step in the group lockout procedure is followed. Our Model Memo refers to this person as the “Designated Employee”.
3. List Elements of the Group Lockout Procedure
Indicate that your group lockout procedures consist of, including:
4. Require Notification by Designated Employee
The rest of the Model Memo sets out the procedures themselves. The first one is for the Designated Employee to notify all workers in the area where the machine is being serviced that the work is taking place. This must happen before the machine is locked out and before any member of the service group can begin servicing the machine.
Compliance Pointer: Notification methods should be based on your basic lockout procedures and involve the providing of written notice to workers in the area. Each of those workers should sign and acknowledge that they received the notice.
5. Require Understanding of the Energy Source and How to Control It
The next step is to remind each member of the group servicing the machine of their individual responsibility to understand the energy source of the serviced machinery and the means of controlling that source.
6. Require Use of the Proper Shutdown Procedure
Next, provide that the Designated Employee must ensure that the equipment has been properly shut down before work begins. To determine what the appropriate shut-down method is, the Designated Employee will have to refer to your company’s basic lockout procedure.
7. Require Locking Out of the Energy-Isolating Device
Require each member of the servicing group to attach an individually lock to the machinery’s energy-isolating device. Tell them that if the machine won’t accept multiple locks, the Designated Employee must lock out the equipment using a single group lock. Specify that the key to the group lock must be secured in a separate lockout box and that each worker in the servicing group must attach his individually assigned lock to the lockout box.
After the energy-isolating device has been locked out and for the rest of the lockout procedure, the basic lockout procedures kick back in. This covers the dissipation of stored or residual energy and disconnection of the machinery from its source(s) of energy. Make it clear that the Designated Employee is responsible for completing the rest of the lockout in accordance with whatever basic lockout procedures your company uses.
8. Set Procedure for Restoration of the Machinery to Operation
Last but not least, explain how the machinery being serviced is to be restored to operating condition once work has ended. Make the Designated Employee responsible for the process and warn that under no circumstances should any other member of the servicing group attempt to restore the machinery to working order unless and until all individually assigned locks have been removed from the energy-isolating device or separate lockbox (depending on which shut-down method you used). Say that the Designated Employee must be the last person to remove his or her individual lock from the energy-isolating device or lockbox.
Once all the locks have been removed, the Designated Employee must finish the restoration process. This will involve:
Lockout/tagout citations are a perennial presence on the list of OSHA top 10 cited violations. A good chunk of these citations are for failure to follow group lockout standards. Following the procedures described here and set out in the Model Memo should go a long way toward keeping your company off the list of companies cited for group lockout violations.