Maintenance Technology September 2017 - 30

PLANT SAFETY MATTERS
must be implemented several times a
day. Loss of time and profits creates
strong incentives to bypass LOTO
when performing repetitive machine
tasks. Disregarding these procedures,
however, violates OSHA requirements
and puts workers in danger.
Thankfully, OSHA 29 CFR 1910.147
also outlines Alternative Protection
Measure (APM) procedures that can
result in increased efficiency without
compromising the safety of the operation. This exception is also referred
to as the minor servicing exception.
Designed for machine tasks that
demand repetitive access, i.e., clearing
a jam on a conveyor or a minor
tool change, alternative measures
do not require that power sources
be completely cut off. Examples of
alternative-measure technologies
include key-controlled locks, control
switches, interlocked guards, and
remote devices and disconnects.
Locking out just a section of a piece
of equipment, rather than the entire
machine, is another approach.

ANSI requirements
The newest ANSI standard, ANSI/
ASSE Z244.1 (2016) The Control of
Hazardous Energy-Lockout, Tagout
and Alternative Methods, agrees with
OSHA in that workers should be
protected from injury due to unexpected equipment startup or release
of potentially hazardous energy. The
ANSI committee, though, did not try
to align fully with every historic OSHA
compliance requirement. Instead, the
new standard gives expanded guidance
beyond OSHA's regulatory limitation to
tasks that are "routine, repetitive, and
integral to production operations".
ANSI makes it very clear LOTO shall
be used unless a user can demonstrate
that a well-established alternative
method will provide effective protection. In situations where the task isn't
well understood or risk isn't assessed,
lockout shall be the default protective
measure applied to control machinery
or processes. Section 8.2.1 of ANSI/
ASSE Z244.1 (2016) specifies that
alternative methods shall only be used
after hazards have been assessed and

30 |

MAINTENANCE TECHNOLOGY

documented through the application of
a Practicability (or Justification) Study
to determine that the techniques used
will result in a negligible risk or no risk
for sudden startup.
Following the Hierarchy of Control

Year after year, lockout/
tagout is one of OSHA's
most frequently cited
violations.
model, ANSI/ASSE Z244.1 (2016)
provides detailed guidance on if, when,
and how a range of alternative control
methods can be applied to result in
equal or improved protection for people
performing specific tasks. In addition,
alternative risk-reduction methodology
is covered in detail specific to a number
of new technologies used in the
packaging, pharmaceutical, plastics,
printing, and steel industries, and
for dealing with certain challenges in
semiconductor and robotic applications.

LEARN
MORE

Navigating the requirements
Since the OSHA and ANSI standards
are somewhat conflicting, it's best
to review ANSI first to help identify
discrepancies that may not meet federal
minimum regulations.
At this point, it would be appropriate
to underscore that LOTO provides
the greatest level of protection and,
whenever possible, it should be utilized
to protect employees from hazardous
energy. In other words, inconvenience
alone is not an acceptable excuse to use
alternative measures. In addition, CFR
1910.147 clearly states that an allowable
alternative measure must provide the
same or greater level of protection as
LOTO. Otherwise, it is considered
noncompliant and therefore insufficient
to replace LOTO.
By using standard safety-rated
devices, such as interlock gates and
e-stop buttons, a plant manager
can achieve safe, reliable machine
access that replaces standard LOTO
procedures without violating OSHA
requirements. Implementing alternative procedures to ensure equivalent
protection for specific tasks can enhance
productivity without endangering
employees. But those procedures-and
their benefits-come with strings
attached, requiring a thorough understanding of the latest OSHA and ANSI
standards. MT
Information was provided by Matt
Brenner, a vice president at Rockford
Systems (rockfordsystems.com, Rockford,
IL), and Todd Grover, global senior
manager of Applied Safety Solutions for
The Master Lock Co. (masterlock.com,
Oak Creek, WI). An ANSI board member,
Grover helped write the Institute's LOTO
alternative-methods code.

For more information on applicable lockout/tagout
standards, see:

Occupational Safety & Health
Administration, Washington,
OSHA.gov

American National Standards
Institute, Washington,
ANSI.org

SEPTEMBER 2017
http://www.rockfordsystems.com http://www.masterlock.com http://www.OSHA.gov http://www.ANSI.org
Table of Contents for the Digital Edition of Maintenance Technology September 2017
