Lockout Tagout

Lockout, Tagout. We're back in general industry now, so a little over 3,000 citations for Lockout, Tagout in 2014,which surprised me because Lockout, Tagout has been around since the 60’s, and we should now have a good handle on Lockout, Tagout. This is an item that is extremely important for worker safety. So we do have to that written documented policy. This goes back to that word ‘documented’. 

So OSHA can come in and ask, "Let me see your Lockout, Tagout policy." You want to have it in writing and make sure that it is readily available for them. You have to audit this program at least once a year. So that means that somebody, maybe the safety manager is going to go out and take a look at one of the workers and make sure that they're following the procedures that are in that written documented policy. I would also develop a form for that, that would be my audit form. The worker would sign it, the safety manager would sign it. And that has to be stored somewhere, that if OSHA does show up, at least they can see that you did go out and audit that program. The last facility I was at, unfortunately, they did have a citation, not because they weren't using Lockout, Tagout, it was because they didn't audit the program, and in OSHA's eyes, if you don't document it, then it never happened. So you got to make sure you come up with that form.

Failure to provide training. OSHA also says, once a year, you have to train your employees on your Lockout, Tagout policy. It would be nice here to make sure that there is some type of little written test, also some type of hands on activity that you can document with pictures, with videos that say, "Yes, we trained our workers on Lockout, Tagout." The other thing that you should remember on all of these policies is enforcement. That if you're don’t enforce it, then you don't have a policy. So if you do see a worker that has been trained in accordance with your policy, you have to go out there and enforce it and have some consequences. If there's no consequences, then you really do not have a policy for that. So enforcement is very important in this area. 

So general electrical requirements. And we have almost 3,000 of these in 2014. Maintain working space about electrical equipment. I know this. In today's world, space is money, but unfortunately, around electrical equipment, we need, depending the voltage, and depending on the area that we are in, what else might be near there, we are going to need at least three feet of minimum working space about our electrical equipment. That means we can't store items in there, that means that when we walk up to that electrical equipment, we don't have to move anything, we just walk up and its free and clear. 

There's three conditions associated with this, and the lowest one is three feet, and then we have another one that's about three and a half feet, and another one that's four feet, depending on the voltage, and depending on what is near it. The condition number three, will tell us that if we have two pieces of electrical equipment facing each other, and one of them is 480, then we need at least four feet. If we just have an electrical panel on the wall, well, then we only need three feet in front of that one. In condition number two would be if we have some concrete in front of that panel, that would be around three and a half feet.

Label all our panel schedules accurately. So think of this, many of you have been in your facilities a long time, there's probably been changes made, maybe those changes did not get reflected on that little panel schedule that's inside that door. In the last company I was in, they had a citation that cost them $50,000. And they looked at me and they said, "What could we have done?" I said, "You could get a circuit tracer, trace those others. Sends a signal on your conductors, and then you have a receiver to pick that signal up, it really can be very beneficial for you." OSHA wants to make sure that if we are de-energizing something, if there's an accident, and we have to get the equipment shut down quickly, that these panel schedules are all labeled 100% perfect. 

This is 110.3D. So, this is a key for OSHA. List of the labeled equipment. So immediately, they're talking about, "Do we have a UL listing on there?" Or CSA, or TUB, or ETI, ETL. There's is a lot of testing, third party testing entities out there, that put their list on their equipment. So they have tested it under laboratory conditions, and they said "As long as you use this equipment in accordance with the instructions, you're not going to have a problem." Well, the minute that we start modifying that equipment, or we use it outside the parameters that the manufacturer gave us, that can be a very big issue with OSHA. 

So cables with damaged insulation or exposed bear conductors, not replaced. And believe it or not, I do see this quite often, that there will be some maybe some 500 casing that is just hanging from the ceiling, and that they're all energized. And I say "Why do you have those?" "Well in case of emergency, this is our backup power." Well, that just can't be, we've got to make sure that because of arc flash blast, we've got to make sure that these cables are intact and ready to go.