Lockout Tagout Regulations in the UKSpectrum Industrial
What is Lockout Tagout?
Lockout Tagout is a safety process defined as the act of turning on/off machinery and tools, locking it in its current state with a Lockout Device and/or Safety Lockout Padlock so it is unusable in order for maintenance or repair to commence.
Lockout Tagout Process Simplified:
- Ensure all machinery (which is to be locked out) is motionless, turn the valve/switch on/off or pull the plug out (removing the key source of power to the machine/pipework that we are locking off).
- Select an appropriate LOTO device. Different Lockout devices are used for different types of energy sources. (see below for more information on energy sources and what Lockout Tagout devices are best used for what energy).
- Close the Lockout Tagout device and lock it shut with a Safety Lockout Padlock (with the valve/handle/plug inside). It is best practice to also include a LOTO Tag to highlight the reason for the machine stoppage.
There are a lot of benefits to using Lockout Tagout Devices, not only is it a simple procedure to implement to ensure employee and contractor safety, it has some key benefits for your company’s efficiency and profitability.
5 benefits of using Lockout Tagout
- Less downtime* (machinery and labour)
- Reduced accidents
- Reduced fatalities
- Higher productivity
- Lower indirect costs (sick pay etc)
*Downtime in this instance represents the time spent by the machine or employee when production has come to a halt due to machine maintenance or repair.
Lockout Tagout (LOTO) is currently in its growth period in the UK, with the process being widely used in the USA, Canada and parts of Europe. It is a growing market, for Health and Safety, Manufacturing, Industrial Services and much more.
In the USA and Canada they use OSHA standards to keep businesses compliant. Using the ‘Control of Hazardous Energy’ Regulation, which states Lockout Tagout to be a must do when it comes to employee safety.
The 1910.147(a)(1)(i) covers 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 standard establishes minimum performance requirements for the control of such hazardous energy.
Whereas in the UK, the main regulation within the manufacturing industry is PUWER.
PUWER stands for the Provision and Use of Work Equipment Regulations 1998 (1999 in Northern Ireland). The regulations deal with the work equipment and machinery used every day in workplaces and aims to keep people safe wherever equipment and machinery is used at work.
This in its essence means that employers should make all machinery safe for use, including precautions such as extra Guards and safer PPE (Personal Protective Equipment). Machinery should also be inspected at regular intervals to ensure it is in a continued ‘safe to use’ state. The UK also looks to businesses to adhere to the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER). This acts as an acknowledgement that businesses with lifting equipment should inspect the lifting machinery regularly. [http://www.hse.gov.uk/pubns/priced/puwer.pdf]. This can be completed through a series of Tagging Systems specially designed to be used in conjunction with machinery labeled as those described as a lifting accessory. Tagging Systems are made up of holders and inserts, the holders are to be fixed to the machinery/tools and the inserts filled in and placed inside of the holder with the inspection details showing. (Click here for more information on Tagging Systems).
There are citations within the PUWER regulations that argue the use of safety devices such as Lockout Tagout, however at no point do the regulations state this outright. But it does explain that ‘lockout devices’ should be used to enhance the safety of employees. So, it may not be written in black and white under English Regulations that Lockout Tagout should be used but the document does mention a ‘Hierarchy of measures’ for standardising safety procedures that are Lockout Tagout related but they are explained as a permanent fixture to any machine or tool. For instance one of the three measures mentioned is to ‘provide protection appliances (jigs, holders, push sticks)’. And as a wider assumption this could include LOTO devices but it doesn’t specifically say that in the regulation. This part of the regulation is more about ensuring that the day to day workplace risks are assessed properly and thoroughly. However in the same set of regulations, it states that employers should ensure that all work equipment is accompanied by an appropriate way to isolate power/energy. Including an appropriate set of actions (and facilities) to turn the power back on without creating a potential hazard for other employees. [http://www.legislation.gov.uk/uksi/1998/2306/regulation/19/made]. This is more aligned with the American OSHA guidelines and practices and defines that the Lockout Tagout Safety movement is on the rise in the UK.
PUWER EU Regulation
For our neighbors in the EU, the guidelines are also OSHA based and therefore pick up on American characteristics in its legislation, but it is 89/655 paragraph 2.14 that states that:
every piece of equipment must be fitted with clearly visible devices with which it can be separated from every energy source
This indicates that all workplace machinery should be fitted with permanent LOTO solutions for easy and safe Lockout Tagout procedures. The EU Regulations are similar to PUWER in that both are concentrated on what the employer can do to ensure the safety of their staff.
I believe that it is only a matter of time before the process of Lockout Tagout including its relevant devices become a mainstream practice within the UK and written into UK Legislation.
Although the act of Lockout Tagout is presented to be best practice throughout many industries and is currently not enforced in the UK there are alot of people within the UK being educated in the ways of Lockout Tagout Procedure. The challenge now is to ensure that people are selecting the appropriate Lockout Tagout Device for their machines and/or tools.
Energy sources and their matching Lockout Tagout Devices
Lockout Tagout Devices are generally manufactured specifically for certain types of energy, to lock out certain types of valves, switches and MCB panels etc. For instance we stock a Gas Cylinder Lockout, designed to fit the top of a Gas Canister to restrict unauthorised usage. Whereas our Cable Lockouts can be used across multiple energy sources including being used alongside other Lockout devices.
Energy Sources VS Lockout Tagout Devices:
|Electrical Energy – Commonly found powering nearly all workplace equipment and charging tools. Electrical Lockout Devices range from Dielectric Padlocks, Dielectric Hasps, MCB Lockouts, Electrical Panel Lockouts, Fuse Lockouts and Plug Lockouts.|
|Hydraulic Energy – Found powering Forklifts, cutting equipment and pumps. Hydraulic Lockout Devices are generally described as Steering Wheel Cover Lockouts, Plug Lockouts and Gate Valve Lockouts.|
|Mechanical Energy – Can be found powering machinery with moving parts. For instance the following can be used – Cable Lockouts, Emergency Stop Lockouts and Plug and Hoist Cover Lockout.|
|Thermal Energy – Found in Fridges, Microwaves, freezers, ovens etc. Thermal energy is mainly created by Electricity and therefore the Lockout Devices used for locking off thermal energy are devices such as Plug Lockout, Pin and Sleeve Lockout and Cylinder Lockout.|
|Pneumatic Energy – Most commonly found powering machinery via compressed air or gas. A stainless steel scissor Pneumatic Lockout System allows the Pneumatic hose to be fitted inside the device to restrict its usage. A Plug Lockout works in the same way by enclosing the hose and/or nozzle inside, again restricting its usage.|
|Potential/Kinetic Energy – Generally found in compressed strings, suspended weights and inside larger machinery. The safest way to Lockout machines that have stored energy is to allow them to come to a complete stop before unplugging or switching the machine. Then using blocks and Lockout devices such as a Plug Lockout or Push Button Lockout you can ensure that re-energisation is prevented.|
What is a Lockout Tagout procedure?
A Lockout Procedure is a process that each piece of machinery is put through during routine maintenance and/or repairs. Not all procedures are the same due to the huge variations in machinery and operating environment. Therefore Lockout Tagout Procedures are often custom written specifically per business premises. There are companies that will visit your premises and write up a LOTO Procedure for you (at a cost) but the process is fairly straightforward.
- Evaluate and Plan – Start by describing all processes currently in place and those are required by law for a successful hazardous energy control programme.Try to describe responsibilities, training, isolation procedures and restoring equipment to normal operation, contractor control, LOTO products, permits to work, etc.
- Equipment Appraisal – Identify all equipment requiring energy isolation during maintenance, cleaning or repair activities. For each item of equipment, gather details of associated energies, isolation points (valves, switches, breakers etc), and the sequence of isolation. Consider environmental factors such as confined spaces, adjacent activities and any essential equipment adaptations. Consider mechanical valves and/or LSS (Life Safety Systems) that are required to remain ON for safety purposes during these activities. Specific “On State” isolation must be included as required and possible downstream effects of same must be risk assessed and documented.
- Equipment Specific Procedures – Use equipment appraisal information to develop equipment specific procedures. This activity also helps define lockout product requirements for each item of equipment or work area. Once proven through testing, equipment specific procedures should be posted alongside the equipment.
- Training, Procedure Awareness & Lockout Tagout products – Equip authorised employees with the relevant lockout products and tags as detailed in the audit. For safety reasons, only products specifically designed for implementation Lockout Tagout procedures should be used.
- Implementation – A new lockout programme involves a workforce having to think and work in a new way, posing a challenge in terms of changing safety culture and mindset. Leadership participation and backing is therefore crucial during planning and implementation stages. Monitor behaviors, listen to the workforce and adapt the programme to ensure it is embraced successfully and exceed corporate and legal requirements.
In conclusion, the above regulations state that employers are responsible for providing the correct procedure for shutting/starting up any workplace machinery, as well as providing safety barriers between the machine and the employee (for example – more guards and permanent Lockout Tagout Devices). In the UK it is not a legal obligation to install Lockout Tagout equipment into the workplace. However it is now seen as best practice across many industries and is known to reduce the amount of accidents, injuries and fatalities.
Contact us for more information on Lockout Tagout, Procedure writing and Tagging Systems.
Provision and use of work equipment regulations 1998 :