MSHA put mine operators on notice in recent weeks that it is concerned about the hazards of improper lock-out/tag-out (LOTO) practices across the industry. Avi Meyerstein at law firm Jackson Lewis comments.
In a recent letter to metal and nonmetal mine operators published by Rock Products magazine, MSHA M/NM Administrator Neil Merrifield promised that in coming months, “MSHA will stress the importance of concentrating on effective lockout procedures by focusing additional resources on increased enforcement and education and outreach, including walk-and-talks” by inspectors and the agency’s Educational Field and Small Mines Services unit.
At the same time, MSHA and the National Lime Association jointly published a one-page alert called “Lock-Tag-Try.” The alert reminds operators of the hazards of stored energy, lists MSHA’s LOTO regulations, provides best practices for LOTO programs, and links to a series of 28 “fatalgrams” by MSHA describing past accidents since 2005, which MSHA blames on lock-out/tag-out failures.
Emphasizing the need to check that an energy source actually is locked out before continuing work, MSHA stresses that “it’s not locked out until you’ve tried it out.” The alert and letter cover both electrical and mechanical energy hazards, reminding operators of the following standards that apply
- 30 CFR §§56/57.12006 – Distribution boxes
- 30 CFR §§56/57.12016 – Work on electrically powered equipment
- 30 CFR §§56/57.12017 – Work on power circuits
- 30 CFR §§56/57.14105 – Procedures during repairs or maintenance
- The latest guidance suggests the following best practices:
- Use Lock – Tag – Try whenever:?– Removing or bypassing a guard or other safety device for maintenance, repair, cleaning, or clearing jammed mechanisms
- Placing any part of one’s body where it could be injured by moving machinery parts or release of stored energy (hydraulic or pneumatic pressure, steam, springs, objects that could fall or pivot), or?– Placing any part of one’s body into an electrical energy or hazardous substances danger zone.
- Identify and control stored energy: mechanical, electrical, hydraulic, pneumatic, gravity, chemical, thermal.
- Identify proper lockout locations – disconnect main or circuit power sources, not on/off switches, interlocks, emergency stops or selector switches.
- Develop machine-specific lockout procedures.
- Each person uses his/her personal, unique lock and tag (no duplicate locks or keys.)
- Clearly defined group lockout procedures may be used for complex jobs involving multiple miners, equipment or energy sources.
- Each person affixes and removes one’s own lock and tag. Verify mechanical equipment is isolated by trying to start or operate it. Electricians verify electrical circuits are deenergized by testing. Keep miners clear of equipment and hazards during the “try out” process
- Use locks only for lockout, not for securing toolboxes or lockers
- Train all miners who use locks and tags on proper procedures. Provide awareness training to other miners
- Address contractor responsibilities and procedures
- Periodically review lockout program. Add or modify procedures when new equipment is installed or procedures. Retrain miners as needed.
MSHA has called attention to LOTO concerns and tips in the past. Its web site includes“The Do’s and The Don’ts” for lock-out/tag-out, as well as a LOTO safety awareness page listing safety tips, best practices, and fatal accidents through 2008 that MSHA said resulted from “failure to follow proper Lock Out / Tag Out procedures.” That page also includes links to four vintage MSHA training videos on lock-out/tag-out.