A BASIC REVIEW OF ENERGY ISOLATION
By Pamela Cordier

My position with the Pulp & Paper Safety Association gives me a great opportunity to hear many different comments, opinions and concerns about safety within our industry. A significant number of those comments and concerns relate to Lockout/Tagout (LOTO) or Energy Isolation.  Certainly, LOTO is one of the most basic of safety topics and 29 CFR 1910.147 remains one of OSHA's most frequently cited standards. There is also no question that the hazards associated with failure to control or isolate ALL forms of energy presents occasions for the most serious of injuries or even fatalities.  But, if it is so basic and has the potential for such serious consequences, why is it so frequently cited for violations and why are so many industrial injuries associated with LOTO?  My conversations with both industry safety professionals and line supervisors lead me to believe that there may be a number of different answers to this question.

29 CFR 1910.147 the control of hazardous energy has been with us for a long time and the potential for injury is readily apparent. It is probably one of the first OSHA standards which companies tried to execute and achieve compliance.   While many aspects of both the standard and practical applications are easily understood, others are vague and lend themselves to various interpretations.  We found that the concept of "zero energy" did not always lend itself to our production process, particularly with some machine set-ups where control power is required and routine interruptions like jams where it is impractical to lockout main power.  The OSHA standard does allow for exceptions to the lockout requirements for minor servicing activities provided that they are routine, repetitive and integral to the production process.  In these cases, we must implement alternative measures that provide effective protection to the employee exposed to the potential hazard.  Apparently some facilities recognize these exceptions to the LOTO standard, but fail to implement procedures that provide effective protection.  Also, one of the safety professionals that I spoke to indicated that in his experience it was the terminology and not the procedure that was to blame.  He found that the alternative procedure that provided effective protection was being properly used, but that their machine operators still called it Lockout/Tagout even though they were using control power.  OSHA of course does not recognize electrical energy isolation any place other than main disconnects. Machine operators must learn that these minor servicing activities are in fact alternative measures and that they are not LOTO.  This particular company has coined the phrase "Energy Safe Procedure" (ESP) to differentiate these activities from LOTO.  Another company uses the term “Zero Energy System” and another uses Safeguard Key Switches System.

In some cases, employers carefully train their employees on LOTO procedures, but establish that their maintenance personnel are the "authorized employees" and as such, are the only ones that are directly involved with energy isolation.  All others are trained as "affected employees", or those that use the alternative measures.  In many cases this may be true, but in many others, it has been found that some employees take the concept of minor servicing activities far beyond the scope and intent of the exception to the standard.  As one safety person put it, "supervisors must realize that it is not who is doing the job that counts, but rather what job is being done".  Anytime the task goes beyond a routine, repetitive, minor servicing activity, LOTO is required regardless of who is performing the task.  Another concern has been raised over the actual terminology of Lockout/Tagout itself.  For some reason, the term LOTO conjures up images of electrical energy, but of course the OSHA standard covers all aspects and all types of energy including steam, hydraulic, pneumatic, residual and even gravity.  To change this concept, some companies have started to use terms like "Energy Isolation", or "Zero Energy" to more clearly define what LOTO is supposed to encompass.

The one concern that seems to be universal is what to do when despite seemingly adequate training, employees still violate LOTO procedures or fail to use proper alternative measures.  This is not only a common concern, but is also one of the most difficult aspects to manage.  I know that some companies have unyielding policies and stringent disciplinary measures for violation of LOTO procedures.  But as I have stressed in previous articles, have we assured ourselves that our LOTO training is current, applicable and practical?  Is the training and observed safe behavior constantly being refreshed and reinforced, or is our training a once-a-year regulatory mandate?  Are we conducting our periodic inspections as required by the OSHA standard?   Are we sure that it is a clear-cut policy violation or did our system fail?  If we do a comprehensive hazard analysis, write concise and easily understood procedures, adequately train all authorized and affected employees, observe and evaluate our procedures and then constantly reinforce them, we will establish the proper and safe way to do the job.  The employees involved in the performance of these tasks should be part of the implementation process.  Energy Isolation is one of the most serious of safety procedures.  The potential for injury or loss of life is enormous if short cuts are taken.  There is nothing in our jobs that is more important than making certain that proper LOTO is part of our safety culture.