Lockout/Tagout and Green Energy Sources
OSHA has established minimum performance requirements for the control of hazardous energy in the workplace which are provided in Title 29 of the Code of Federal Regulations (CFR) Part 1910.147 . These regulations cover the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could harm employees. This accidental activation is called an "uncontrolled release of hazardous energy."
According to OSHA’s website showing the 2019 ” top 10 most frequently cited standards following inspections of worksites by federal OSHA,” Control of Hazardous Energy (lockout/tagout) is ranked as #4. And unfortunately, the number of citations associated with lockout/tagout is moving up the list; it was ranked as #5 in 2018. During the period from October 2019 through September 2020, a total of 1,762 citations were issued for these types of violations. Those citations resulted in over $11.4 million in fines levied against the companies who were cited by OSHA.
As stated by OSHA, they publish the list each year “to alert employers about these commonly cited standards so they can take steps to find and fix recognized hazards addressed in these and other standards before OSHA shows up. Far too many preventable injuries and illnesses occur in the workplace.” One of the best ways to avoid citations and fines, but more importantly how to keep your employees safe and alive, is to develop and implement a robust Lock-Out/Tag-Out program and detailed LOTO procedures. Using software such as LOTOBuilder will provide you with the tools needed to 1) write your LOTO Program, 2) develop your site/equipment specific LOTO procedures, 3) set up a system to communicate the program and procedures to your employees, 4) implement inspection protocols and reminders, and 5) build an internal safety culture that will ensure on-going compliance with OSHA requirements.
Lockout/tagout is a concern in a wide variety of industries, but as shown by the OSHA statistics, over 79% of the citations issued fall into manufacturing categories. And in 2019, private industry employers reported 2.8 million nonfatal workplace injuries and illnesses, and of those, manufacturing accounted for 15% of the total (Source: U.S. Bureau of Labor Statistics). The statistics also show that 25% of nonfatal occupational injuries and illnesses occur due to “contact with an object or equipment (e.g., struck by, struck against, or caught in or compressed by object). Not controlling energy sources in the workplace can not only result in citations, but significant injuries and/or death may occur when hazardous energy is not controlled. Injuries may include electrocution, burns, crushing, cutting, lacerating, amputating, or fracturing body parts, and others. OSHA provides the following examples:
- A steam valve was automatically turned-on burning workers who were repairing a downstream connection in the piping.
- A jammed conveyor system suddenly released, crushing a worker who was trying to clear the jam.
- Internal wiring on a piece of factory equipment electrically shorted, shocking the worker who was repairing the equipment.
When one of your employees is injured, or possibly killed, not only do you risk citations and fines, but your insurance premiums will go up, your client base may suffer, and your employees may leave as well. Implementing a solid lock-out/tag-out program is one way to keep all these things from occurring!
Individual industries or manufacturing types have different levels of risk, and different needs and approaches for managing those risks. And as the U.S. and other countries work towards new sources of “green energy” to address climate change, concerns associated with implementing lockout tagout procedures must be considered. Specifically, “green sources” of energy such as wind, solar, biofuels, geo-thermal and hydroelectric bring up new hazards when it comes to the potential release of uncontrolled energy. Let’s look at some of the potential LOTO concerns with a couple of these emerging, and continually changing industries, specifically wind energy and solar energy.
In their article about “ green job hazards, OSHA talks about the potential hazards associated with working on wind turbines. Because wind turbines have a lot of internal machinery and equipment, including blades that need to be maintained, workers performing servicing or maintenance may be exposed to injuries from the unexpected energization, startup of the machinery or equipment, or release of stored energy. Wind farm employers must implement lockout/tagout procedures outlined in OSHA standards.
In their curriculum developed through a grant from OSHA, the Center for Career Development and Employability Training (CCDET) at the University of Wisconsin Oshkosh, developed a training booklet covering Safety and Health in Wind Energy Strategies for Small Wind Energy Businesses. (PDF Download) The booklet presents the following procedures for Lockout/Tagout:
- The circuit or equipment must first be de-energized.
- Every person working on the circuit or equipment must verify that the system is deenergized prior to starting work.
- Every person working on the system must employ his/her own lock to isolate the energy.
- The locked system must be properly identified with tags to indicate the system must not be tampered with.
- As each person completes his/her task, they remove their padlock and tag.
- Before re-energizing the system, all covers and panels must be securely re-attached.
- A system cannot be re-energized until the final lock is removed.
- People who perform lockout/tagout must be trained
- Employees who work around locked and tagged equipment must be trained on the hazards of electricity and the importance of leaving the locks and tags intact.
Because of the nature of wind turbines, the potential for serious injury including death, precautions must be taken but more importantly, a rigorous LOTO program must be implemented. According to an article written by Mick Sagrillo called Lock-Out / Tag-Out for Small Wind, he notes that:
“When working around small wind turbines, a frequently-overlooked safety issue is voltage in wires running up the tower as well as at the turbine. Turbine installers and maintenance personnel often have to check continuity of wire runs or circuits at the wind turbine. If the tower must be climbed, three critical aspects demand the utmost attention: gravity, proper use of the safety harness, and the potential for an electrical shock. Even if a shock is not fatal, it can be disorienting enough to cause a fatal fall.”
It should also be noted in addition to the lockout/tagout requirements provided in 29 CFR §1910.147, companies that work on and maintain wind turbines must also be in compliance with the energy control provisions of 29 CFR §1910.269 which covers industrial establishments which engage in the generation, transmission, and distribution of electric power [specifically §1910.269(d)]. This regulation requires the employer to “establish a program consisting of energy control procedures, employee training, and periodic inspections to ensure that, before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start up, or release of stored energy could occur and cause injury, the machine or equipment is isolated from the energy source and rendered inoperative.“
Employing a program like LOTOBuilder can provide wind equipment installers and maintenance workers with a platform to develop, review, update and share LOTO procedures. Once a LOTO procedure is written for the task at hand, it can easily be opened and shared on any device having an internet connection, and can be updated, evaluated and approved from the LOTOBuilder dashboard.
Solar is a growing sector for green energy and green jobs. Various worker health and safety hazards exist in the manufacture, installation, and maintenance of solar energy. Employers working in the solar energy business need to protect their workers from workplace hazards and workers need to understand how to protect themselves from hazards.
In their Safety and Health Topics article covering green jobs, OSHA identifies two commercially viable solar energy sectors: 1) solar electric and 2) solar thermal or solar water heating.
Solar Electric: Solar energy can be converted into electricity using photovoltaics (PV), or concentrating solar power (CSP). PV systems are the most common and use semi-conductors and sunlight to make electricity. The more solar modules a PV system or array has, the more electricity will be generated. Materials presently used for photovoltaics include monocrystalline silicon, polycrystalline silicon, microcrystalline silicon, cadmium telluride, and copper indium selenide/sulfide.
Solar Thermal or Solar Water Heaters: Types of solar water heating systems include direct and indirect (Glycol) systems and are chosen largely by climate; freezing temperatures can damage some types.
Workers in the solar energy industry are potentially exposed to a variety of serious hazards, such as arc flashes (which include arc flash burn and blast hazards), electric shock, falls, and thermal burn hazards that can cause injury and death. Solar energy employers (connecting to grid) are also covered by 29 CFR §1910.269 (Electric power generation, transmission, and distribution); as stated above, this standard requires that employers implement robust lockout/tagout programs and procedures.
Implementing a strong health & safety program that includes a well-written and thorough lockout/tagout program as well as detailed LOTO procedures can help minimize or eliminate the types of hazards that could result in solar installers being shocked or suffering thermal burns. LOTOBuilder provides the user with an option to upload their own LOTO Program or use the written program that is already available within LOTOBuilder. Then, LOTOBuilder allows the user to create lists of covered equipment, lists of affected employees, inspection protocols and reminders, and detailed descriptions of how to properly use and apply locks and tags.
In a recent blog post by Fluke, they talk about the inherent hazards associated with working around photovoltaic (PV) systems. They state that “the need to de-energize the system applies when installing, inspecting or performing maintenance on PV systems,” but they also note that “de-energizing those systems can be a bit trickier than standard electrical systems.” They define the energy from PV modules as “wild” - meaning that “it varies with the sunlight and is not controlled by electronics. Even under cloudy conditions and at night, there is the potential for shock hazard with a PV system.”
The article goes on to say that “although PV modules can never be completely de-energized, the ac output of the inverter can be de-energized, and the dc voltage reduced to acceptable levels. The modules in a string can be manually disconnected to reduce the voltage to individual modules. Or you can use module-level power electronics, such as power optimizers and microinverters, which automatically reduce module voltage when the ac breaker is switched off.”
The Oregon Solar Energy Industries Association (OSEIA), on behalf of Oregon OSHA, developed a guidebook titled Solar Construction Safety (Guidebook) which provides information to help employers (and employees) develop safe work practices for typical solar construction projects, and can be used as a basis for training. As stated by the Guidebook, “Solar construction crews face many of the same conditions found in typical construction trades with notable exceptions that underscore the nature of both solar electric and solar hot water equipment: exposure to sunlight creates stored energy not present in other construction trades. Managing this energy safely is an important aspect of solar construction.”
The Guidebook provides recommendations and procedures for identifying and eliminating (or minimizing) hazards associated with a variety of aspects of working in the solar industry including: general jobsite safety, lifting safety, ladder safety, fall protection, trip hazards, solar plumbing safety, and solar electrical safety. The module on solar electrical safety provides guidance to recognize electrical hazards and keep workers from being shocked or electrocuted. As stated, “working on or near electricity can be very dangerous. The term electrocution refers to death from electrical shock. Electrocution is the third-leading cause of work-related deaths among 16- and 17-year-olds. Electrocution is the cause of 12% of all workplace deaths among young workers.”
“Electrical shock occurs when you complete a path for current to flow through your body. The risk of shock is always present in live electrical circuits. Since electric current will take the path of least resistance to ground, if you contact a live circuit and complete a path to ground or to another circuit, you will get shocked.”
Shocks can be minor resulting in a very sharp pain. Shocks can also cause serious injury or death such as:
- Severe burns.
- Convulsions leading to ventricular fibrillation and internal injury.
- Numbness, tingling, paralysis.
- Vision, hearing, or speech problems.
Getting shocked can also lead to falls from rooftops or ladders, leading to fall related injuries. Although, in general, the higher the voltage the higher the risk, it’s possible that electric currents of as little as 100mA can induce ventricular fibrillation, disrupting your heart’s normal blood pumping operation, resulting in convulsions and possibly death. In comparison, a typical house electrical service of 120vAC can produce currents thousands of times higher than 100mA.”
Preventing electric shock by working on de-energized circuits is a key to electric safety. Following are some items to consider when working on electric circuits.
1) Always de-energize circuits before beginning work on them.
- You can’t get shocked by a de-energized circuit. Unfortunately, many electric accidents have been caused by assumed ‘dead’ circuits. Working safely on circuits includes testing them for hazardous energy prior to working on them.
- Use a meter or circuit test device such as a current clamp to ensure the circuit is dead prior to working on it.
2) Implement circuit lock and tag out rules
- Lock out the power on systems that are capable of being locked out. Remember that the lock out tag is not for the person that you are aware of and that knows you are working on the electrical circuit – it’s for the person you don’t know and that doesn’t know you are working on the circuit. You must notify all affected persons.
- Tag out all circuits that you’re working on at points where that equipment or circuit can be energized.
The National Institute for Occupational Safety and Health (or NIOSH) has a lot of very useful resources regarding the control of hazardous energy. In their publication titled Preventing Worker Deaths from Uncontrolled Release of Electrical, Mechanical, and Other Types of Hazardous Energy (Publication No. 99–110), NIOSH recommends that that employers implement the following steps to prevent injuries and deaths of workers who must work with hazardous energy in their jobs:
1. Comply with OSHA regulations.
2. Implement a hazardous energy control program.
3. Identify and label all sources of hazardous energy.
4. De-energize, isolate, block, and/or dissipate all forms of hazardous energy.
5. Establish lockout/tagout programs requiring individually assigned locks and keys to secure energy control devices.
6. Verify that all energy sources are de-energized before work begins.
7. Inspect repair work before re-energizing the equipment.
8. Make sure that all persons are clear of danger points before re-energizing the system.
9. Train workers in the basic concepts of hazardous energy control.
10. Include a hazardous energy control program with any confined-space entry program.
11. Design machines and systems that make it easy to control hazardous energy.
Development of a hazardous energy control program can easily be done using LOTOBuilder’s proprietary lockout/tagout software. The software, which is cloud based so there is nothing to download or update, leads the user through the development of their LOTO program, and then provides an easy-to-use method for developing specific procedures for individual pieces of equipment where the specific sources of hazardous energy can be clearly identified. The program allows the user to upload pictures of specific lockout and tagout points as well as the equipment to be used to ensure that the energy source has been properly deactivated and stays that way until the maintenance or repair work is completed, and the person in charge has removed their locks and tags. LOTOBuilder would be a great tool for developing procedures to manage the control of hazardous energy in any green industry!