Lockout Tagout and Confined Space Program Misconceptions
CONAN REED, GSP • North Texas Industrial Project Manager • BS in Occupational Safety and Health, Murray State University • 3 Years with W&M 2
NICK FOREMAN, CSP • NTX EHS Compliance Division Manager • B.S. in Biology, Texas A&M University • Master of Public Health, Texas A&M University • 12 Years with W&M 3
By The Numbers • Failure to control hazardous energy accounts for nearly 10% of all serious accidents. • Lockout Tagout is a top 10 most frequently cited standard.
Lockout/Tagout Program Misconceptions “I don’t need a program because we use contractors to complete maintenance activities and our employees do not perform lockout/tagout.” • Using contractors reduces the risk to your employees, but the hazard is not eliminated. • The liability still falls on your company even when using contractors. • OSHA defines an affected employee i s an employee whose job requires him or her to operate or use a machine or equipment on which servicing or maintenance is being performed that is under lockout or tagout, or whose job requires him or her to work in an area in which such servicing or maintenance is being performed. • OSHA requires that affected employees are trained to an awareness level, and understand the purpose and use of energy control procedures, and about preventing them from attempting to remove a tag and/or lock. 6
Lockout/Tagout Program Misconceptions “We won’t be using this equipment for a long period of time, lets lock it out with our lockout tagout lock and tag.” • Lockout tagout is for servicing and maintenance • Use an out of service lock and tag. • Out of service locks and tags must be different from lockout tagout locks and tags. • OSHA requires that the locks must only be used for the control of hazardous energy, and not for any other purposes. • The locks must also be singularly identifiable, which will help prevent any confusion in lockout/tagout scenarios. 7
Lockout/Tagout Program Misconceptions “Our operators can clear jams in machines by using the E-stop instead of lockout/tagout” • OSHA defines clearing jams as servicing and/or maintenance under OSHA’s lockout/tagout standard. • E-Stops still leave employees at risk of undesired hazards. • E-Stops do not provide effective energy isolation and/or control. • E-Stops may be effective if combined with other energy control devices for minor servicing. 8
Lockout/Tagout Program Misconceptions “We don’t need to do lockout/tagout because our machines have interlocked guards that shut down the machine during maintenance.” • Interlocks use control logic to stop the machine, but electrical power is still being supplied. • The goal of lockout/tagout is to completely de-energize the machine before any work is completed on the machine. • One machine can have multiple sources of energy. 9
Lockout/Tagout Program Misconceptions “Only One Person Needs to Lock Out and Tag Out the Equipment for a Team to Work on it.” • Each employee working on that piece of equipment should apply their personal lock to the equipment. • Designed to eliminate unintentional accidents/incidents from a person thinking everybody is in a safe place when somebody is still working on the machine. 10
Lockout/Tagout Program Misconceptions “A LOTO Lock has to be a Keyed Lock.” • A lockout device can be “either key or combination type”. • Only one person can know each locks combination. • Makes the use of a lockbox more difficult. • Don’t have to carry the key all the time BUT, you have to remember the combination. • Must be as effective as a key lock. 11
Permit Confined Space Program Misconceptions
What Is a Confined Space? Confined Space – • Is large enough for an employee to enter fully and perform assigned work. • Is not designed for continuous occupancy. • Has a limited or restricted means of entry or exit. Permit-Required Confined Space – • A confined space with one or more of these characteristics: • Contains or potentially contains a hazardous atmosphere. • Contains a material with potential to engulf someone who enters the space. • Has an internal configuration that might cause an entrance to be trapped or asphyxiated… inwardly converging walls, floors sloped to smaller cross-section, etc. • Contains any other recognized serious safety or health hazards. 13
Permit-Required Confined Space Program Misconceptions “My employees do not enter permit required confined spaces, we use contractors, so I do not need a program.” • Contractors must be informed of permit-required spaces on site. • Contractor must be given of all the procedures, polices, elements, hazards, and any experienced work that makes the space a permit- required confined space. • Entry operations must be coordinated. • A debriefing must be performed between contractor and host. 15
Permit-Required Confined Space Program Misconceptions There is often confusion if a confined space is permit required or not. • Go back to the definition: Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics: • Contains or has a potential to contain a hazardous atmosphere; • Contains a material that has the potential for engulfing an entrant; • Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross- section; or • Contains any other recognized serious safety or health hazard. 16
Permit-Required Confined Space Program Misconceptions The space has a potential to contain a contaminant above the OSHA PEL. • Is this a serious safety or health hazard? • An atmosphere that contains a contaminant above the PEL does NOT make the space permit required. • It does NOT prevent self rescue. • It is covered in 1910 Subpart Z. 17
Permit-Required Confined Space Program Misconceptions “We Don’t need a program, our employees only enter non permit- required spaces.” • A confined space assessment must be made. • Some permit spaces may be reclassified to non-permit. • Confined space program must contain reclassification procedures. • Reclassification ONLY after elimination of Hazards. • Space is permit-required until the hazards are eliminated. • The space still needs to be assessed as permit-required. 18
Reclassifying A Permit-Required Confined Space Allowed to Vent - Remove mixer Air Monitoring Might be Disconnected from Any Required Depending on Other Equipment or What Was in the Space Tanks Labeled as PRCS Chemical Contents Removed Steam Lines Disconnected Allowed to Cool to Ambient Temperature 19
Example Confined Space Entry Permit (1 of 2) 20
Example Confined Space Entry Permit (2 of 2) 21
Addressing Common Misconceptions • A strong safety culture remains a priority for our clients, but there are still misconceptions about program requirements. • Safety experts at W&M can help address these misconceptions, assess and bridge gaps in compliance, and ensure these programs are implemented safely. • W&M will provide comprehensive training, to help employers avoid risk and/or injury to their employees. 22
Addressing Common Misconceptions • You can’t always trust Google: • These are some of the results when you search “non permit-required confined space” 23
CONAN REED, GSP creed@braunintertec.com 972-509-9614 24
NICK FOREMAN, CSP nforeman@braunintertec.com 972-509-9609 25
May’s Webinar 26
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