Mike Mechanic has done his morning safety check of lift A and found the brake needs adjustment. It is about 20 minutes before opening time, so Mike hurries back to the shop and gets the tools he needs to adjust the brake. The door to the control room is locked, so he figures he can climb into the engine room and quickly fix the switch before the lift staff arrive. But today, the lift staff arrive early. They unlock the control room door and start the lift. Mike gets his hand caught in a rotating part and goes to the hospital instead of home for the day. Mike’s hand is amputated due to his injuries.
Snowmaking circuit 4 had blown fuses the previous night at Resort Mountain. The area’s electrician, Ellen, comes in to work on the troublesome circuit. She arrives in the afternoon before the snowmaking staff has begun to set up for the night. She finds that one of the 480 volt outlets has a bad wire at the outlet box. She returns to the switchgear that provides power for that outlet and shuts it off. The mountain manager assures her the staff will not be in for another hour, so she has time to repair it without interrupting operations. Supervisor Sam arrives to get operations going and realizes that the power for one of the snowmaking circuits they need that night is shut off. He promptly turns it on. Ellen is electrocuted.
These horrific scenarios could have been prevented if Mike and Ellen had followed a lockout/tagout (LOTO) procedure, and if their respective resorts had LOTO policy and training in place.
LOTO is required under OSHA regulation 1910.147: “The control of hazardous energy,” to remove or secure any energy source before work is started. This applies to any equipment that has stored or residual energy that may cause an injury if released or applied while being serviced. Energy sources can be electrical, mechanical, hydraulic, pneumatic, thermal, and gravitational. All may be present in the resort environment—as when servicing lifts, water pumps, snowmaking systems, or lighting systems.
Energy control procedures must be developed for each machine or device requiring lockout. Procedures must provide a clear, step-by-step process for an employee to follow to control any type of hazardous energy while working on equipment. Lockout is more secure than tagout, and is the preferred option. Lockout typically refers to a procedure that will prevent the release of hazardous energy by placing a mechanical device, such as a padlock, to prevent another person from activating an energy source. It may also be a block to stop some type of gravitational force, for example. The procedure depends on the type of energy being controlled, but in all instances a written procedure must be in place.
Tagout means “placement of a tag or label identifying a hazardous energy source to warn others not activate the energy source.” It is only allowed when lockout is not feasible. To facilitate lockout, since 1990, regulations require all machinery be designed or redesigned for lockout, including older models undergoing major repairs and modifications.
LOTO violations are the sixth most frequently cited by OSHA. Between 2008 and early 2015, approximately 7 percent of OSHA-issued citations to ski resorts were related to LOTO violations, and 17 percent of the resorts undergoing an OSHA inspection were cited for LOTO, either for not having procedures in place or for not following the LOTO standard. These citations resulted from either a complaint or referral due to an injury, or a planned OSHA inspection program.
What to Do About LOTO
The resort (employer) is responsible for writing LOTO procedures and training employees in them. The LOTO training program must be done so all understand and gain the proper skills and knowledge to safely conduct LOTO. Retraining must be done when there is a change in equipment, process, or energy control procedures. Retraining is also necessary when an employee appears to inadequately perform LOTO or a machine has been redesigned or replaced. And of course, training must be documented, including the employee’s name and date.
Training is one of most important aspects of LOTO. There are two levels to this training: one for “authorized employees” and one for “affected and other employees.” The level of training depends on the employee’s involvement or job tasks related to a machine. Lift mechanics, lift operators, snowmakers, ski patrol, electricians, machine repairmen, etc., are all likely candidates for LOTO training.
During training, authorized employees must demonstrate they recognize hazardous energy sources and understand the methods and means for controlling and isolating hazardous energy. Affected and other employees need to understand when LOTO procedures are being used and the importance of them.
For example, in the first scenario above, Mechanic Mike should have used LOTO before working on the lift, and the lift operators should have understood that LOTO was in place for repairs.
Employers must also do a periodic inspection—at least once yearly—of workers who are conducting LOTO. The aim is to review the employee’s responsibilities and knowledge related to the LOTO procedures. The inspection must be documented and include the control procedure (machine) reviewed, review date, employee, and person performing the review. This is an important section of the regulation that many employers fail to follow.
The periodic inspection should verify that the LOTO procedures are being done as written, checking that employees, both authorized and affected, understand the LOTO, and determine if any changes are needed to the procedures.
Any lockout device must be attached and removed only by the person conducting the service. If more than one person or department is servicing a machine or equipment, then a group lockout must be utilized. Only the person who applied the lockout device may remove it when his or her portion of the job is complete.
For example, if a chairlift breaks down with guests on it, requiring a possible evacuation, both a mechanic and ski patroller must lock out the lift. They will apply two locks to the energy source—the main electrical supply, say—one managed by each employee. Only the mechanic can remove the mechanic’s lock, and the ski patroller, the patrol’s lock. The two locks must be keyed differently, and the keys must be controlled by the person who applied the lock. These employees remove the locks only after the evacuation is complete or the lift is repaired, and all personnel are clear.
Energy lockout procedures must be fully documented. The basic steps:
1. Notify affected employees.
2. Authorized employee(s) review machine’s LOTO procedures and energy sources.
3. Shut down the machine.
4. Release or isolate energy sources.
5. Take specific steps to lock out device.
6. Remove any stored residual energy.
7. Verify energy is disconnected from machine.
8. Follow restart procedures and LOTO removal once work is complete.
LOTO procedures should be posted next to the machine. Best practices include a photograph or diagram of the LOTO location(s) with the LOTO device(s) in place. The procedures can be placed in plastic or laminated sleeves. They should also be part of the employee training on each machine.
Each machine must have its own LOTO procedure. If three lifts are identical, say, the same procedures can be used, but the procedures must be posted at each location.
Employees working in areas that require LOTO can help write the needed procedures—they are more likely to use procedures that they helped develop.
Effective LOTO procedures will keep employees safer and more confident. Any accident affects all employees. They can eliminate or reduce the chance of life-changing accidents such as those portrayed in the beginning of this article. And that’s good news for everyone.