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By Steve Benda and Robin Kressin, Labelmaster
A comprehensive lockout/tagout (LOTO) program not only helps to keep power generating plants compliant with OSHA regulations, but also increases productivity and contributes to the safety of employees. Plant accidents involving machinery can be devastating to personnel and the company’s bottom line. The power generating industry as a whole has been successful in implementing a tags-only program. Its success can be attributed, in part, to extensive operations personnel training and their specific plant equipment access limitations.
However, even with the proven successful safety history, the power generating industry still finds its LOTO violations on OSHA’s top 10 most frequently cited list. This has caused many plant operations managers to re-evaluate their existing methods and investigate better ways of implementing their LOTO programs. They find that there have been significant advancements in locking and tagging support devices and methods as well as enhanced interpretive provisions to the regulations. These factors have an impact on reducing implementation costs.
To create an optimal clearance (LOTO) program, the power generating industry should rely on a combination of the standards contained in 29 CFR 1910.147, 29 CFR 1910.269 and 29 CFR 1910.333. Adherence to all three of these regulations will produce an acceptable and effective LOTO program. A power generating plant contains equipment and systems specific to the generation of power and other equipment or systems not associated with the power generation, such as office lights, cafeteria equipment, sump pumps and the like. Creating one LOTO program to cover all scenarios within a power generating facility is a desirable strategy. A more comprehensive program that moves beyond “tags only” is an important step toward achieving the power generating industries LOTO best practices.
Toward Tags-Plus
First, it is important to understand the background supporting this required transition from “tags only” to “locks and/or tags-plus”. In 1989, OSHA implemented 29 CFR 1910.147. OSHA believed that implementing this industry-wide general environmental control would prevent injury from inadvertent or unexpected energization of equipment or systems to industry personnel. This regulation specifically exempted installations under the exclusive control of electric utilities for the purpose of power generation, transmission and distribution, including related equipment for communication or metering; and exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations. Although the power generating industry was exempted from 29 CFR 1910.147, OSHA promised to implement a regulation specific to the industry.
 Safety is enhanced by adopting a comprehensive LOTO program. |
In 1994, OSHA fulfilled that pledge and implemented 29 CFR 1910.269 known as the Power Generating Standard or the 1994 Standard. The 1994 Standard is taken nearly verbatim from 29 CFR 1910.147 and therefore imposed known and specific requirements for tagout or lockout methods when performing lockout and tagout procedures within a power generating facility.
Understanding that energy systems within a power generating facility include those systems exclusively intended to support power generation and other systems to support general plant operations, two scenarios exist for creating an acceptable LOTO program within the confines of a complete power generating plant. The first scenario is where a power generating facility relies on an existing 29 CFR 1910.147 program and requires the addition of the enhanced provisions. The second scenario is where a power generating facility relies on an existing or newly created 29 CFR 1910.269, section 1910.269(d) program and adds the requirements of two of the enhanced provisions: Tags used without a lock; and a qualified person shall use test equipment. A detailed description of these enhanced provisions follows.
System Operator Provision – This is a provision that is an important requirement for power generating facilities in that it recognizes that plant generating systems are operated by highly trained qualified systems operating personnel only. This provision permits system operators to “place and/or remove lockout and tagout devices in place of the authorized employee” when the energy isolating devices are installed in central plant areas inaccessible to the authorized employees. These systems are under the exclusive control of the system operator. This system operator provision is limited, however, in that it applies to central plant locations accessible only to operations personnel. Thus it does not apply to energy isolation devices located in general plant areas.
 Locks and tags are becoming power industry standard. |
This provision works in conjunction with LOTO group methodologies which ensure each authorized employee is uniquely accounted for and that each individual is the only person who can release his or her personal lockout device, personal tagout device, or equivalent means of controlling hazardous energy sources.
Tags Used Without a Lock – According to OHSA’s Directive Number CPL 2-1.38, Enforcement of the Electric Power Generation, Transmission, and Distribution Standard dated June 18, 2003, OSHA has determined that lockout is a more effective means of ensuring the de-energization of equipment; indeed, it is the preferred method. If the energy isolation device is capable of being locked out, the standard requires that lockout be used unless the employer can demonstrate that tagout will provide “full employee protection,” (also referred to as “tags-plus”); that is, a level of protection that is equivalent to lockout. 29 CFR 1910.333 states “When a tag is used without a lock, the tag shall be supplemented by at least one additional safety measure that provides a level of safety equivalent to that obtained by use of a lock. Examples of additional safety measures include the removal of an isolation circuit element, blocking of a controlling switch, opening of an extra disconnecting device.” 29 CFR 1910.147 and 29 CFR 1910.269 require the same.
A Qualified Person Shall Use Test Equipment – A qualified employee is required to use test equipment to verify all circuit elements and circuit parts are de-energized prior to potential employee exposure. This testing will determine if unexpected energization can occur due to an induced voltage or unrelated voltage backfeed even after the specific parts or circuits have been checked and verified de-energized. A “qualified employee” is an employee who has received specific training and is competent in the skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment, to determine the nominal voltage of exposed live parts, knowledge of safe approach distances to exposed parts and proper use of pre-cautionary techniques, personal protective equipment, insulating and shielding material and insulated tools for working on or near exposed energized parts.
The power generating industry is transitioning from a tags-only clearance program to one that utilizes locks and tags and a combination of both. Not only does a specific regulation mandate this transition, but the industry is finding the advancements in locking and tagging support devices (coupled with better documented and actual individual authorized personnel accountability) reduces the chances for personal injury, minimizing operational costs. These advantages have encouraged plant operations management to reevaluate their clearance methods. In many cases, they have revised their programs to utilize better practices and enhanced locking and tagging devices. A useful tool in helping plant operations personnel to work toward implementing LOTO best practices is to conduct a self audit, like the one provided here.
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Authors: Robin Kressin is manager of Business Development for Labelmaster. During her 20-year career she has worked with the power generation industry to find solutions for increasing safety and productivity. Robin holds a master’s of business administration degree from Marquette University and participates in various safety and construction professional associations. Steve Benda is a consultant for Labelmaster. For the past 17 years, he has focused on developing effective and simplified lockout and tagout products and methods. He currently holds 21 patents, 16 of which are related to locking and tagging apparatus. Steve graduated from Michigan Technological University with a Bachelor of Science degree in Electrical Engineering.
