30 Safety First

Updated OSHA Lockout/Tagout May Increase Productivity

Hazards are ever-present in the Safety is a challenge that all compa- Unfortunately, these are some of steel plant environment, and nies face and many still think add- the very reasons that lockout/tagout a heightened awareness and ing safety devices or safety systems is not always used, used incorrectly, emphasis on safety is a necessary to machinery reduces productiv- or machine guards and safety sys- priority for our industry. This ity. This can be true in many cases tems are bypassed. monthly column, coordinated by because, quite often, important On 20 May 2019, OSHA post- members of the AIST Safety & steps are overlooked in the imple- ed a request for information (RFI) Health Technology Committee, mentation process. Unfortunately, it to help with its investigation into focuses on procedures and is not uncommon for safety system the use of control circuits in the practices to promote a safe designers to have a knee-jerk reac- lock out/tagout process: working environment for everyone. tion and implement safety solutions “This RFI seeks information that limit access and prevent per- regarding two areas where mod- sonnel from doing their jobs. This ernizing the lockout/tagout stan- often results in bypassed safety solu- dard might better promote worker tions that are ultimately removed safety without additional burdens and ignored. The same is true for to employers: control circuit–type lockout/tagout (LOTO) solutions. devices and robotics. OSHA’s lock- As a matter of fact, lockout/tagout out/tagout standard currently violations are always on the top 10 requires that all sources of ener- list of U.S. Occupational Safety and gy, including energy stored in the Health Administration (OSHA) vio- machine itself, be controlled dur- lations, as shown in Fig. 1. ing servicing and maintenance of Author Some companies are starting to machines and equipment using Christopher D. Brogli implement modern safety control an energy-isolating device (EID). global vice president of safety solutions to improve safety and pro- Control circuit–type devices are business development, ROSS ductivity, and they are using these specifically excluded from OSHA’s Controls, Troy, Mich., USA [email protected] alternative solutions to enhance definition of an EID and are thus their manufacturing processes. not a compliant method of control- Solutions include energy isolation ling hazardous energy during ser- systems that isolate multiple sources vice and maintenance activities. But of hazardous energy such as pneu- technological advances since the matic, hydraulic and electric. There standard was issued in 1989 suggest have been a number of OSHA letters that, at least in some circumstances, of interpretation allowing systems control circuit–type devices may like these to be used as an alterna- be at least as safe as EIDs. OSHA tive measure or method to lockout/ requests information, data and com- tagout for specific tasks. However, ments that would assist the agency anyone who is familiar with OSHA, in determining under what condi- lockout/tagout, alternative mea- tions control circuit–type devices

AIST.ORG sures and machine guarding knows could safely be used for the control I there is a gray area for what is of hazardous energy.”1 Comments are welcome. allowable without obtaining a vari- For background, OSHA listed If you have questions about this ance from OSHA. This leads many a recent Nucor Steel Connecticut topic or other safety issues, please companies to err on the side of cau- Inc. variance from April 2016 which contact [email protected]. tion, perhaps leading to more down- involved a trapped key solution and Please include your full name, time due to the complexity of their it was specifically stated that: IRON & STEEL TECHNOLOGY

I company name, mailing address lock out/tagout procedure, start-up “OSHA evaluated whether the and email in all correspondence. issues and/or guarding that can device provided an equivalent level make safe operator access difficult. of employee personal control over JUN 2020 31 machine re-ener gi za tion, Figure 1 ability to account for exposed employees and verification of isolation to that required by the OSHA standard. OSHA reached three conclusions. First, OSHA concluded that the alternate device allowed energy control measures to remain under the personal control of the exposed employee through control of the trapped key using a group lockbox. Second, OSHA concluded that employees were able to verify de-energization. Third, OSHA concluded that autho- The top 10 list of U.S. Occupational Safety and Health Administration’s most cited violations. rized employees were easily identified before equipment restart.”1 OSHA then provided a list of 33 questions regarding the use of control-type machinery to go to the safe condition when required devices, what special considerations should be taken or requested and prevent workers from overlooking when using robots, what types of tasks should be an energy source due to inadvertently or deliberately allowed when using control systems for energy isola- missing a step. There also are concerns over things tion instead of lockout/tagout, and what the cost and such as task creep (performing tasks not authorized training impacts would be from use of these types of for the alternative measure) or utilizing safety systems systems. Replies were due by 19 August 2019 and 87 that have not been verified and validated against the replies were submitted from manufacturing organiza- safety system requirements. These are existing issues tions, companies and a number of individuals. and will still have to be dealt with through the use of Most public comments were in favor of OSHA administrative controls (procedures). updating the 1989 standard: 29 CFR 1910.147, The Control of Hazardous Energy (lockout/tagout). Many cited the use of modern safety control systems, which Public Comments Submitted to OSHA did not exist in 1989, and have since been recognized in various consensus standards, such as ANSI/ASSP American Forest & Paper Association (by Stan Lancey) Z244.1-2016. — “The current LOTO standard has a substantial Other common themes in the comments were that inherent weakness because the primary control mea- while OSHA wrote about control devices, it was really sures are all behavior dependent. Protective measures control “systems” that they were referencing. Any con- that are heavily and repetitively behavior dependent trol system that is used to control hazardous energy suffer from tremendous variability and are far less sources must be part of a redundant safety system reliable than engineered safety control systems.”2 that is designed to be fail-safe. These “safety control systems” must be designed with consideration of the Design Safety Engineering Inc. (by Bruce Main) —

function, reliability and failure modes of all the input, Apfeld (2011) references a 2006 German study and JUN 2020 logic and output devices in the system. In keeping expands on the content as follows: “It is a well-known with the classic tenets of lockout/tagout, each employ- fact that protective devices on machinery are bypassed. I ee that is exposed to a hazard must have exclusive The HVBG report entitled “Bypassing of Protective IRON & STEEL TECHNOLOGY control of the machine through some sort of trapped Devices on Machinery” was the first to deliver reli- key, lock or presence-sensing device. able statistics, data and facts on the phenomenon. As it stands, lockout/tagout is an administrative It has now been shown that approximately 37% of control whose effectiveness is entirely dependent all protective devices on metalworking machines upon workers correctly following the procedure are bypassed in this way. The machines concerned I in order to safely perform the task(s) in question. present a substantially increased risk of hazard and AIST.ORG Properly designed alternative measures for hazard- likelihood and severity of accidents. Ultimately, the ous energy control (safety control systems) cause the bypassing of protective devices can be avoided only if 32 JUN 2020 I IRON & STEEL TECHNOLOGY I AIST.ORG Technologies (by Bryan Griffin) — Griffin) Technologies Bryan (by ANSI and ISO standards for designing safety control safety for designing standards ISO and ANSI The reality is that many companies are embracing embracing are companies many that is reality The Safety First Experiences in the packaging industry have shown have shown industry packaging the in Experiences vides this framework, but perceived conflict with the the with but perceived conflict framework, this vides want and need from OSHA is a clear process, clear clear process, aclear is OSHA need from and want that alternative methods are a very effective means to to means effective a very are methods alternative that sorely needed. are methods of alternative use the task being performed prevents many employers prevents many from performed being task of confi a lack in rooted are issues safety above the that bypassing or defeating risk reduction measures is is measures reduction risk or defeating bypassing that trol system failures. The implication of this research research of this implication The failures. system trol tive measures cannot be used. be cannot measures tive gray into the fall lockout/tagout that tional for tasks Potential Improvements Potential — Thatcher) Jake (by Automation Rockwell Processing and for Packaging Association — The PMMI ure to provide workers with practical means to safely safely to means practical workers provide with to ure benefits, i.e., no incentive exists. Whether these data data these Whether i.e., no incentive exists. benefits, be acceptable to OSHA, but many are still using tradi using still are but many OSHA, to acceptable be prevent injury because they do not they rely on employee because prevent injury prevent tasks from being performed, or are cumber or are performed, being from prevent tasks that systems Safety well be. may tasks certain perform is not a primary cause of workplace injuries, but afail of workplace injuries, cause notis aprimary control of systems the or reliability quality the that is packaging industry, and likely many other industries, industries, other many likely and industry, packaging possibly invite unwanted scrutiny. What companies companies What scrutiny. unwanted invite possibly and years take can which OSHA, from avariance ing language in the regulation and focus on the type of type on the focus and regulation the in language lockout/tagout can create other hazards, or where lockout/tagout hazards, other create can where or difficult, lockout/tagout time-consuming is requirements and clear limitations as to when to alterna as limitations clear and requirements of a framework to justify the decisions made about made decisions the justify to of aframework methods. Updated regulatory requirements that allow allow that requirements regulatory Updated methods. machines are designed such that defeating offers no offers defeating such that designed are machines control systems can be used on any machine where machine on any used be can control systems fate and are afraid of taking on the process of obtain process on the of taking afraid are and fate dence about how to interpret the regulation and lack lack and dence regulation about how the interpret to duction process, where setup requires power, where requires setup where process, duction actions.” applying it.”applying Z244.1 (2016) ANSI in pro outlined energy ardous a primary cause of harm to persons, rather than con than rather persons, to of harm cause a primary indicates research current or not, the universal are area. They do this because they are reluctant to tempt to reluctant are they because do this They area. safeguarding. The methodology for controlling haz for controlling methodology The safeguarding. some to use, do not fare well in practice.” well in do notsome use, to fare standards, yet by necessity make use of alternative of alternative use make yet by necessity standards, OSHA outdated how comply to with with struggle systems that allow faster access for tasks they know will will know they for tasks access faster allow that systems safe access is required repetitively as part of the pro of the part as repetitively required is access safe Where and why would these systems be used? Safety Safety used? be systems why these would and Where 5 4 “Companies in the the in “Companies 3 “Many of “Many ------Manual energy isolation lockout isolation valve. energy Manual valve system. valve bleed and block safety Hydraulic channel). (dual Redundant valve. double exhaust safety Pneumatic channel). (dual Redundant to provide uptime/productivity data. Many injuries injuries Many data. uptime/productivity provide to multiple zones of control are required. Anumber of multiple required. zones of control are for bypassing safety systems, but not many for safety but not for safety many systems, safety for bypassing are recorded for lockout/tagoutare not following or submissions included data on injuries and downtime downtime and on injuries included data submissions Figure 2 Figure 3 Figure 4 33 control system failures. Uptime is highly dependent Safety control systems should include pneumatic on the time required to perform lockout/tagout ver- and/or hydraulic safety valves that block supply pres- sus using an alternative measure, and on commute sure and exhaust/bleed energy from the machine times from lockout points and access points on the resulting in a “zero energy” state (where needed). machine. Today, there are new technologies that accomplish The steel industry is a perfect place for these types the lockout/tagout process in a repeatable, controlled of systems to be implemented due to the size of the and systematic manner. These systems use remote- machinery, the various energy sources, and the inabil- controlled energy isolation devices in combination ity to simply lock out an entire machine for tasks that with remote lockout stations and control logic to must be accomplished quickly and thoroughly on “automate” the lockout/tagout process. Exclusive con- a repetitive basis. As more companies take Nucor’s trol is still provided through the use of remote lockout approach, they will find more and more opportuni- stations (RLS) that are lockable. The RLS stations ties to implement advanced safety control systems. are connected to safety relays and/or safety program- Companies that are interested in finding areas for mable logic controllers (PLCs) that monitor the status improvement may likely find examples in their facili- of the inputs and outputs of the system to control asso- ties where their employees are currently working on ciated energy isolating devices like electrical contrac- machinery with single-channel safety systems that tors (that disconnect the electrical energy) as well as do not meet state-of-the-art standard requirements pneumatic and hydraulic safety valves that “block and regarding redundancy and monitoring for control of bleed” the fluid power energy. Below is an example of electrical, pneumatic and hydraulic energy sources, such a system. and as such, are potentially putting themselves at risk. Systems like the one shown in Fig. 5 utilize a remote In the past, OSHA has required the isolation of lockout station at each access point on the machine pneumatic and/or hydraulic energy to be done only to reduce the travel times from the access point to through the use of direct-operated, lockable manual the lockout point for each energy source to reduce valves like the one shown in Fig. 2. This would con- the number of steps in the lockout/tagout process tinue to be the case because, for tasks that require by locking out multiple energy sources from a single disassembly of machinery, removal of guards, and/or lockout point. These remote lockout stations tell the bypassing of safety devices, this type of energy isola- monitoring safety relay or safety PLC to start the isola- tion device is the best possible device to use. However, tion process. The safety relays/PLC tells each energy the hope is that OSHA will see that for the multitude isolating device to de-actuate and relieve all energy. of other minor servicing and setup tasks that need to Monitoring switches, sensors and feedback circuits be done, there is great benefit in the expanded use tell the safety relays/PLC that a safe state has been of safety control systems for the control of hazardous achieved. Then, the safety relays/PLC turns on the energy. “Energy Isolated” light on the remote lockout station

Figure 5 JUN 2020 I

IRON & STEEL TECHNOLOGY

(a) (b) I AIST.ORG

There are a number of qualified safety integrators in the market that can provide steel mills with design and implementation assistance for this type of modern safety control system: example circuit (a) and example of hardware and software (b). 34 JUN 2020 I IRON & STEEL TECHNOLOGY I AIST.ORG The use of remote technologies like these improve: these like of remote technologies use The The use of remote technologies like these reduce: these like of remote technologies use The Newer machines are already being designed with such with designed being already are Newer machines Safety First American Foundry Society – AFS (by Juliette Juliette (by –AFS Society Foundry American technology. Control circuit technology will not elimi will technology circuit Control technology. greatly. increase would use their devices, circuit trol but where it can be used it has several advantages. advantages. several it has used but be where it can letting the operator know that it is safe to enter to the it safe is that know operator the letting nate the need for physical disconnects in all situations, situations, all in disconnects need for the physical nate Garesche) — Garesche) machine. • • • • • • VISIT USAT BOOTH #2525 WE’LL BEAT AIST WWW.SCHUST.COM Adherence company to policies. The number of steps in the lockout/tagout the in number of steps The process. The temptation to bypass a cumbersome lockout/ a cumbersome bypass to temptation The Walking distance. Uptime and productivity. and Uptime Missed procedural steps. procedural Missed tagout process. process. tagout meets your needs. Contact Schust at1-800-408-4820 totailorasolutionthatbest operations andmake your working environmentclear again. Schust outofyour take scrap the fumeandtheworry cutting Scrap cutting fumeisdifficult tocapture,butseeingitisnot.Let YOUR PAYBACK PROTECT ech 2020!

“If OSHA were to allow the use of con use the were allow to OSHA “If SCHUST A MEMBEROFTHESCHE UCH GROUP - -

1. 4. For example, its use can reduce the incentive to defeat incentive to reduce the can For use its example, while productivity is increased. Step by step, the per bystep, Step the increased. is productivity while References use of modern safety solutions, safety is enhanced enhanced is safety solutions, safety of modern use is changing for the better. OSHA can play a positive apositive play can for better. the OSHA changing is review and update the 1989 lockout/tagout standard. 1989 lockout/tagout the update and standard. review they improvements as productivity and role safety in ception that safety costs companies time and money and time companies costs safety that ception the With competitive. be to want also butments, they complex operations easier, faster and safer.” and easier,complex faster operations of restart make it and can systems safety or bypass 2. 5. 3. 6. Every company wants to comply with safety require safety comply to with company wants Every

https://www.regulations.gov/document?D=OSHA-2016-0013-008. https://www.regulations.gov/document?D=OSHA-2016-0013-0055. https://www.regulations.gov/document?D=OSHA-2016-0013-0066. https://www.regulations.gov/document?D=OSHA-2016-0013-0056. https://www.regulations.gov/document?D=OSHA-2016-0013-0051. “Department ofLabor:OccupationalSafetyandHealthAdministration.” gov/content/pkg/FR-2019-05-20/pdf/2019-10247.pdf. Federal Register, Vol. 84,No.97,19May2019,https://www.govinfo.

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