Workers can get hurt while performing maintenance and repairs on various kinds of energized equipment, such as table saws, conveyors, mixers, etc. The best way to protect workers is to ensure that the equipment is in a zero energy state while the work is conducted. De-energization involves more than simply turning the power off. Steps must also be taken to ensure that nobody turns the power back on, either intentionally or inadvertently. In addition, stored energy could activate parts of the machine while a worker is making repairs. That’s why the OHS laws require energized equipment to be “locked out” before repair and maintenance work can be done.
Here’s what you need to do to comply with these requirements.
LOCKOUT POLICY & PROCEDURE:
Defining Our Terms
This article focuses on lockout requirements for equipment operated by electricity or another form of energy, as opposed to requirements for “electrical equipment,” that is, equipment designed to generate, supply or transmit electricity.
HOW TO COMPLY WITH LOCKOUT REQUIREMENTS
So how do you ensure that your company complies with lockout requirements?
Take these five steps:
Step #1: Develop Lockout Policy
Although the OHS laws don’t specifically require companies to have written lockout policies, adopting such policies is still a good idea. At a minimum, a lockout policy should cover:
- The types of energized equipment that have to be locked out;
- The activities that can’t be performed on such equipment until lockout is effected, such as repairs, maintenance and activities that require removing guards from or disabling other safety devices of a machine;
- The training workers must have to lockout machinery and equipment and to work on locked out equipment;
- How lockout procedures will be developed, reviewed and updated; and
- How the lockout policy and procedures will be enforced.
LOCKOUT POLICY & PROCEDURE:
Step #2: Develop Lockout Procedures
In contrast to lockout policies, the OHS laws in nearly all jurisdictions do require companies to have written lockout proceduresthat cover the steps to be taken to make sure machinery or equipment can’t be turned on, intentionally or accidentally, while work is carried out on them. Lockout procedures should include the steps to be taken for work carried out by individual workers and by groups of workers. Each set of lockout procedures should address the following:
- Safely bringing and keeping a machine at “zero energy”—that is, inoperable, isolated from any energy source, such as electrical, thermal, hydraulic, pneumatic, chemical, mechanical or steam sources and with any residual energy in the system dissipated;
- Properly placing appropriate lockout devices on the machine, including where and how they should be placed;
- Verifying lockout effectiveness and testing for a zero energy state;
- Notifying people that a machine has been locked out, such as through the use of tags or signs;
- Making sure the area near the locked-out machine is kept clear until the machine is repaired and re-energized again;
- Removing lockout devices, including who may remove them, when and how; and
- Re-energizing the machine after lockout is no longer needed.
LOCKOUT POLICY & PROCEDURE:
Step #3: Provide Workers with Personal Locks
For workers to comply with the lockout procedures, the company will need to provide them with locks. To prevent workers from circumventing the lockout, it’s essential that only the worker who puts a lock on a piece of equipment (or a supervisor) is able to remove it. For that reason, you’re not allowed to use combination locks for lockout purposes. The lock should also identify the worker to whom it belongs with a unique mark or identification tag in case supervisors or co-workers need to contact that person to remove the lock, such as in an emergency or at the end of a shift.
Step #4: Train Workers on Lockout Procedures
As with all safety procedures, it’s crucial to train workers on the lockout procedures and ensure that they understand this training. Who should get lockout training? All workers should understand what lockout is in general, what the locks/tags mean and the procedures to follow if they want to operate equipment that’s been locked out. In addition, any workers who may need to lockout a particular piece of equipment should be trained in the written procedure for that equipment. And if workers could be reassigned to other equipment, they must be fully trained in the lockout procedures for the alternate equipment. Also, workers who may have to deal with any contractors, such as outside service providers, who may be called in to repair equipment or machinery must be trained on the lockout procedures to ensure that those procedures are followed before contractors begin work on the equipment or machinery. Training should generally cover:
- The importance of lockouts;
- Legal requirements for lockouts;
- Company policy on lockouts;
- The energy forms, hazards and procedures (administrative and work-related) that must be followed;
- The importance of following lockout procedures;
- Lockout errors to be avoided, such as assuming the equipment is inoperable or that the job is too small to warrant a lockout;
- The use and care of PPE; and
- Proper use of all tools, including locks.
Step #5: Enforce and Update Policy as Necessary
Failing to comply with the company’s lockout procedures, such as by not locking out equipment or removing someone else’s lock, can have terrible consequences—both for workers and the company. Example: A worker was greasing a die machine when he inadvertently stepped on a pedal that turned on the machine. The die came down on his forearm, crushing it. An Ontario MOL investigation found that the machine hadn’t been locked out. The company pleaded guilty to a lockout violation and was fined $60,000 [IMT Corporation, Govt. News Release, Feb. 11, 2010]. Thus, it’s critical that you enforce the company’s lockout policy and procedures by disciplining workers who violate it. It’s also important to keep the policies and procedures up-to-date. For example, you may need to revise the procedures when new equipment is introduced into the workplace or when the lockout requirements in your jurisdiction change. Of course, any time you change the lockout procedures, you must retrain workers.
THE BOTTOM LINE
Companies have a duty to protect workers both while using equipment and machinery for their intended purpose and when repairing and maintaining that equipment. A lockout policy and procedures are essential to ensuring that your company fulfills that duty.
WHAT THE LAW SAYS
All Canadian jurisdictions address lockout in their OHS regulations in either a dedicated lockout section or as part of their general sections on machinery and equipment. In any event, the lockout requirements in the OHS laws generally cover the following areas:
- When lockout is required, such as when doing repairs or maintenance on energized equipment or when a guard is removed;
- Any exceptions to the lockout requirements;
- General lockout procedures;
- Requirements for individual workers, including issuance of personal locks;
- Group lockout requirements;
- How locked out equipment and machinery should be restored to operation, including removal of locks; and
- Alternatives when lockout isn’t “practicable.”
|KNOW THE LAWS OF YOUR PROVINCE Here’s what your jurisdiction says about when locks are required—and when they’re not|
|LOCKS REQUIRED||LOCKS NOT REQUIRED||RELEVANT SEC. OF THE OHS LAW|
|FED||When a guard has been removed from a machine so that repair or maintenance work can be performed on it.||No specified exceptions.||OHS Regs., Secs.|
|AB||a) When machinery or powered mobile equipment must be serviced, repaired, tested, adjusted or inspected; b) when piping, a pipeline or a process system containing a harmful substance under pressure must be serviced, repaired, tested, adjusted or inspected; and c) when a safeguard for machinery has been removed or made ineffective and the machinery can’t be controlled by a worker.||No specified exceptions.||OHS Code 2009, Part 15|
|BC||a) When the unexpected energization or start-up of machinery or equipment or the unexpected release of an energy source could injure a worker; and b) when machinery or equipment is shut down for maintenance.||Lockout isn’t required if: a) the energy isolating device is under the exclusive and immediate control of the worker at all times while working on the machinery or equipment; or b) a tool, machine or piece of equipment that gets power through a readily disconnected source of power, such as an electric cord or quick release air or hydraulic line, is disconnected from its power supply and its connection point is kept under the immediate control of the worker at all times while work is being done.||OHS Reg., Part 10|
|MB||a) When a safeguard has been removed or made ineffective; and b) when a machine is serviced, repaired, tested, cleaned, maintained or adjusted.||No specified exceptions.||Workplace Safety and Health Reg., Secs. 16.14-16.18|
|NB||When a machine must be cleaned, maintained, adjusted or repaired.||No specified exceptions.||OHS Reg., Secs. 239-240|
|NL||a) When the unexpected energization or start-up of machinery or equipment or the unexpected release of an energy source could injure a worker; and b) when machinery or equipment is shut down for maintenance.||Lockout isn’t required if: a) the energy isolating device is under the exclusive and immediate control of the worker at all times while working on the machinery or equipment; or b) a tool, machine or piece of equipment that gets power through a readily disconnected source of power, such as an electric cord or quick release air or hydraulic line, is disconnected from its power supply and its connection point is kept under the immediate control of the worker at all times while work is being done.||OHS Regs. 2009, Part IX|
|NT/ NU||When machinery or equipment is shut down for maintenance or repairs.||No specified exceptions.||General Safety Regs., Secs. 141-149|
|NS||When work is performed on a machine, equipment, tool or electrical installation and the work is hazardous to a worker if the machine, equipment, tool or electrical installation is or becomes energized.||No specified exceptions.||Occupational Safety General Regs., Part 6|
|ON||When the starting of a machine, transmission machinery, device or thing may endanger a worker’s safety.||No specified exceptions.||Industrial Establishments Reg., Sec. 76|
|PE||a) When machinery or equipment is shut down for cleaning, maintenance or repairs; and b) when a safeguard on machinery has been removed or rendered ineffective and the machinery can’t be directly controlled by the worker.||No specified exceptions.||OHS Regs., Secs. 30.6 – 30.7|
|QC||a) Before any maintenance, repair or unjamming work is performed in a machine’s danger zone; and b) when a worker must remove a protector or protective device to access a machine’s danger zone for adjustment, unjamming, maintenance, apprenticeship or repair purposes.||No specified exceptions.||Reg. on Health and Safety, Secs. 185 – 186|
|SK||Before a worker undertakes the maintenance, repair, testing or adjustment of a machine.||No specified exceptions.||OHS Regs., Sec. 139|
|YT||a) When a worker could be injured by the unexpected energization or start-up of machinery or equipment or the unexpected release of an energy source; and b) when machinery or equipment is shut down for maintenance work.||Lockout isn’t required if: a) the energy isolating device is under the exclusive and immediate control of the worker at all times while working on the machinery or equipment; or b) a tool, machine or piece of equipment that gets power through a readily disconnected source of power, such as an electric cord or quick release air or hydraulic line, is disconnected from its power supply and its connection point is kept under the immediate control of the worker at all times while work is being done.||OHS Regs., Part 3|
Safeguarding v. Lockout
Safeguarding and lockout are similar ways to protect workers from being harmed by energized machinery and equipment. The differences:
Safeguarding: the use of guards to prevent workers from contacting hazardous parts of machinery and equipment is designed to protect workers operating such machinery and equipment.
Lockout: protects workers when machinery or equipment is shut down for maintenance, including repairs and clearing jams.
Some jurisdictions provide guidelines and other resources on compliance with lockout requirements. Here are links to some of those resources: