Optimizing Safety and Efficiency with Alternative Lockout Tagout Measures

If you work in the safety profession or with heavy machinery, you've probably heard of Lockout Tagout. This guideline has significantly reduced the frequency of fatalities and injuries in all general industrial workplaces. Although there have been various adjustments and enhancements to how we implement OSHA 1910.147 over the years, the regulation has never evolved. Controlling Hazardous Energy (Lockout/Tagout) has become a constant struggle for many safety personnel. It is understandable why, every single year, LOTO is in OSHA's top ten violations.

The concept of machine lockout tagout (LOTO) appears straightforward: Identify and isolate energy sources, lock and tag, and conduct the necessary operations, but when it comes to repeating the same method on every machine, LOTO becomes significantly more difficult. In today's competitive global market, capitalizing on every productivity aspect is critical, including efficiency with safety procedures.

Alternative Protective Measures

Although LOTO procedures safeguard personnel who work on machines, the time required to establish, supervise, and train in procedures diverts attention from production. As thorough as LOTO operates, it is often time-consuming, frequently taking more time than the actual repair job on the equipment. Production comes to a standstill, ultimately causing the day's production to be skipped.

Some service tasks done during the regular production process are exempt from the Lockout/Tagout standard's purview. This is known as the minor servicing exception. To maintain or boost efficiency, many supervisors prefer to adopt alternative protective measures, instead of Lockout Tagout processes. The key to employing it is to reduce maintenance work hazards by using machine guarding or other efficient protective solutions. The broader discussion that follows is intended to give additional information on the application of the minor servicing exceptions as well as suggestions for how specifically excluded jobs can be done safely through the use of specialized control devices, work practices, employee training, and other measures.

OSHA and ANSI Standards on Alternative Procedures

The OSHA and ANSI’s LOTO standard discusses the alternative measures required to avoid dangerous energy discharge from equipment and machinery while personnel repair, maintain, and clean them.

OSHA STANDARD
OSHA 29 CFR 1910.147 provides "Alternative Protection Measure" (APM) practices that increase efficiency and productivity without jeopardizing the operator's safety. Alternative Measures are designed for machine tasks that necessitate regular repeated access, such as cleaning a conveyor jam or making a small tool change, and do not demand that power sources be totally shut down. When employees perform duties while the machine or equipment is energized throughout the regular production system, machine guarding must be implemented in line with OSHA's machinery and machine guarding regulations.

ANSI STANDARD
The ANSI standard, "ANSI/ASSE Z244.1 (2016) The Control of Hazardous Energy - Lockout, Tagout, and Alternative Methods," acknowledges OSHA standards that employees should be safeguarded from injury caused by sudden equipment restart or the release of potentially hazardous energy. According to ANSI, LOTO must be used unless the operator can prove that a reliable alternative approach would provide appropriate protection. Furthermore, alternative risk-reduction methods are detailed for a variety of technological developments, such as the packaging, pharmaceutical, plastics, printing, and steel sectors; semiconductor and robotic applications; and others that are constrained by present regulatory constraints.

When are Minor Servicing Exceptions Used?

The first step in developing alternative protection measures is understanding the difference between normal production operations and maintenance procedures requiring LOTO. The Occupational Safety and Health Administration describes service and maintenance requiring Lockout Tagout as "employment practices such as constructing, installing, setting up, adjusting, inspecting, altering, and maintaining machinery or equipment." Normal production activities, on the other hand, are described as "the operation of a machine or equipment to accomplish its intended industrial duties."

Slight device adjustments and improvements, as well as other minor service and maintenance functions undertaken during regular plant operation, are not supported by the OSHA guidelines if they are routine, repetitive, and integral to the utilization of the equipment for production, provided the work is carried out using alternative measures that provide effective protection. For machine operations such as modifying settings, data, temperature, and motion or testing reasons, or when repairing electrical circuits or pressurized systems, there is a need for alternate ways of protection.

Alternative procedures may be used for die switching, clog clearance, lubrication, tool replacements, roll cleaning, minor cleaning, adjustments, and set-up. Based on these characteristics, the administrator should delegate work that is "regular, repetitive, and integral to production" and then carry out a risk analysis. If the jobs do not match these criteria in a significant way, LOTO must be employed.

These solutions could include selective lockout procedures to appropriately lock out a portion or a piece of equipment rather than the full machine. These measures may also include special preventive measures, such as interim barriers positioned over hazardous exposures, special tools, and wide-ranging mechanisms, instead of hand or body interaction, in addition to obstructing or controlling devices which would accurately halt any unexpected machine activity that could harm workers.

Conclusion
When it comes to safeguarding personnel from dangerous energy, safety experts must take a moment to reflect and determine if comprehensive Lockout Tagout, and total de-energization, is required or whether alternative measures of protection may be used. While the eventual aim is to eliminate risks via development, this is seldom achieved. Risk analysis must evaluate the adequacy of constructed safeguards and their degree of reliability for the amount of risk management necessary. As with standard LOTO energy control procedures, the employer must document the alternative control measures systems in a procedural format and teach staff to distinguish between the necessity for LOTO and the usage of alternative protection measures.

The employer may consult the LOTO Experts at E-Square Alliance for deploying accurate procedures and training on the alternative procedures and partial LOTO.