Machine Guarding and Lockout Tag Out: An Important Part of Employee Safety

Machine Guarding

Employee exposure to unguarded or inadequately guarded machines is prevalent in many workplaces. Workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and over 800 deaths per year, according to Federal OSHA data.

As an employer, it is your responsibility to “guard” and protect your employees against the hazards of moving machine parts. OSHA defines a guard as, “a barrier that prevents entry of the operator's hands or fingers into the point of operation.”  Successful and compliant guarding requires employers to understand and validate your safety systems and its components. You must also assess the risks of utilizing specific machinery and applying fundamental machine guarding choices.

Machine guarding is a primary focal point in OSHA inspection due to the multitude of implications that can occur if non-compliant.  MMA-Environmental has participated in numerous OSHA inspections throughout the years; machine guarding is always one of the most frequently looked at and cited violations.

From press brakes, horizontal band saws and bench grinders to automated robots and mixing machines, OSHA has been ensuring the appropriate steps are being  taken to keep employees safe, no matter what kind of machinery. This includes:

• Safe guarding points-of-operation (area where work is being performed; cutting, shaping, forming, etc.),
• Power transmission devices (flywheels, pulleys, belts, chains, gears, etc.),
• Operating controls

All of these are key to keeping your employees safe during associated job tasks.

Each machine has certain safeguard requirements that need to be in place. For example,

• If a safety interlock or point of operation guard is not functioning properly
• A blade guard is not covering an exposed saw blade
• Pinch point potentials are present

These are all issues that need to be addressed promptly as the potential for serious injury is greatly increased. 

It is recommended that periodic inspections of facility equipment are completed to confirm that machine guards are still intact, operational and are adequately preventing employee exposures.

Hazardous Energy Control: Lockout Tag Out 1910.147

One of the most cited violations of the OSHA standard 29 CFR 1910 is Lockout Tag Out, or Hazardous Energy Control. This can also be one of the most misunderstood rules and one most employee tend to be non-compliant with following. Some of the most common issues with Lockout Tag Out are:

Lack of procedures

Procedural checklists are employed as part of the seven step shutdown preparation process for energy control, providing “directions” on how to successfully isolate the operating energy sources of a machine. Specific procedures need to be written for each piece of equipment or process that identifies all energy sources and the energy isolation devices. (Note: OSHA requires a specific written procedure when a single lockout device will not achieve a zero energy state. {29 CFR 1910.147(c) (4)}

Training employees

Most employers do a good job of training those employees who apply locks and tags, “authorized employees,” and those who operate the machines where locks and tags are installed, “affected employees.” But OSHA requires awareness training for a category of employees called “other employees.” Other employees must be apprised of the purpose of Lockout Tag Out program; the energy control devices used, and directed to leave the locks and tags alone. {29 CFR 1910.147 (c)(7)(I)(C)}

Wrong use of tags

Energy control tags are used as information tags or process control tags. The only use for your Lockout Tag Out tag is strictly for Lockout Tag Out. Any other use degrades the importance of the tag. {29 CFR 1910.147 (c) (5) (ii)}

Wrong use of locks

Lockout locks are sometimes used for tool boxes and lockers. As above, the energy control locks only purpose is for energy control during servicing and maintenance. Every employee must respect the hazardous energy control lock. {29 CFR 1910.147(c) (5) (ii)}

Working under someone else's lock

OSHA’s standard and best practices require each employee servicing a piece of equipment to apply his or her own lock and tag for personal energy control. Some employers mistakenly let only the supervisor or area lead apply a lock and tag for a group. No individual should take responsibility for the safety of another employee, where Lockout Tag Out is necessary. {29 CFR 1910.147(d)}

Not identifying all energy sources or stored energy

Turning off an electric switch by itself does not always control all hazardous energy. Multiple electric lines running to a machine, pneumatic power, hydraulic, gravity and kinetic energy are often overlooked. The written procedure must identify all energy sources and methods to dissipate any stored energy sources.  {29 CFR 1910.147(b) & (c) (4)}

Annual audit of procedures and review of findings

OSHA requires an annual audit of each procedural checklist and a review of the audit findings with each authorized employee, where lockout is used. The audit should determine if all energy sources have been identified, are correct for the equipment and if the energy control procedures are able to be understood and followed. {29 CFR1910.147(c)(6)}

Maintenance vs. minor routine

Do employees de-energize and lock out when they change a light bulb, change a drill bit or change a grinding stone? They need to know the difference in servicing and maintenance versus minor, routine adjustments and what is allowable under normal production operations. {29 CFR 1910.147(a) (2)}

Duplicate keys

OSHA addressed this concern in a letter to an employer, which duplicate keys should not be on hand to remove locks. This makes lock removal too easy when an employee who applied the lock has left a facility. Authorized employees need to ensure they are removing and communicating to other employees that they have removed the Lockout Tag Out when they are completed with the work or shift. Cutting a lock should be a last resort.

Year after year Lockout Tag Out is on the top ten most frequent citations from OSHA, indicating Lockout Tag Out is often not followed correctly. The lack of compliance with hazardous energy sources (lockout tag out) and adhering to procedures can lead to numerous citations form regulatory agencies. Additionally, incorrect use of Lockout Tag Out often leads to serious injuries and even death.

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If you have questions or concerns about these, or other, OSHA violations, reach out to an MMA-Environmental representative for assistance.