Lockout/tagout standard successful in saving lives
The Occupational Safety and Health Admini-stration completed a look-back review of its Lockout/Tagout Standard, 29 CFR 1910.147, and all indications are that the regulation achieved its goal.
The review indicates these achievements:
- The standard protects 3.3 million workers at 1 million facilities.
- It has reduced fatalities from unexpected activation of machinery at facilities in the automobile and
steel-making industries by 20% to 55% in the years since its promulgation.
- There is still a substantial amount of noncompliance.
- The standard does not impose a significant impact on small business.
- Public commenters agree that the standard should remain in effect.
Based on this review, OSHA concludes that the Lockout/Tagout Standard should be continued without change and that OSHA should continue to improve its compliance assistance in this area, says Joseph Pipkin, director of electrical and mechanical engineering standards in Washington, DC.
The standard establishes requirements employers must follow to disable machinery and equipment and to prevent the release of potentially hazardous energy during the servicing and maintenance of that machinery and equipment.
The standard requires employers to develop and implement lockout/tagout programs and train their workers to follow required procedures during servicing and maintenance work.
"Lockout" refers to the practice of installing a lock on an energy-isolating device, such as a circuit breaker or shut-off valve, so that the equipment will not be energized by mistake. The term "tagout" refers to the practice of attaching a warning tag to an energy-isolating device to warn employees not to energize the equipment until the warning tag has been removed.
OSHA specifically asked for comments on eight aspects of the rule, including:
- the benefits and utility of the rule in its current form or in an amended form;
- potential feasible alternatives to the rule;
- the continued need for the rule;
- the complexity of the rule;
- evidence of overlap, duplication, or conflict between the rule and other federal, state, and local rules;
- information on economic, technological, and other material changes since the promulgation of the rule;
- alternatives to the rule or portions of the rule that could minimize significant impacts on small businesses;
- the effectiveness of the rule as implemented by small entities.
Comments were received from employers, unions, trade associations, safety organizations, the Small Business Administration, and others.
These are some findings from the review:
- The standard is necessary to protect employee safety and health; compatible with other OSHA standards containing lockout/tagout provisions; not duplicative or in conflict with other federal, state, or local government rules; not inappropriately burdensome; and consistent with President Clinton’s priorities and the principles of EO 12866.
In addition, although the standard is technically complex, compliance assistance materials will assist employers in interpreting the standard. Further, no changes have occurred in technological, economic, or other factors that would warrant revision of the standard at this time.
- The standard protects approximately 3.3 million employees working at 1 million firms. There is some evidence that the level of compliance could be improved. The standard is generally one of the five standards most frequently cited by OSHA compliance officers for violations.
- The most typical situation covered by the standard is to protect employees from death or injury when a machine is unexpectedly turned on by an operator while another employee is servicing or repairing the machine. For example, accidents often occur when one employee is inside the equipment or has his or her hands inside a press to repair or adjust it, and another person inadvertently turns on the machine, crushing or amputating the repair worker’s limb.
Three sources of data were submitted to the docket that demonstrate the rule’s effectiveness: data from the United Automobile, Aerospace, and Agricultural Implement Workers of America (UAW) fatality database; data from a similar database maintained by the United Steelworkers of America (USWA); and data from a study of sawmill injuries in Maine.
The UAW database shows a significant decline in lockout-related fatalities. In the years between 1989 (when the final rule was published) and 1997, lockout-related fatalities declined by 20% per year. When the concomitant increase in the proportion of auto workers exposed to lockout hazards is taken into account, the UAW contends that a 30% annual decline in the rate of these fatalities has occurred.
The USWA database tells a similar story: during a seven-year period (1990-1997), a 55% reduction in lockout/tagout-related fatalities occurred at the 10 basic steel-producing companies represented in the database.
The third study involved an epidemiological analysis of wood product industry workers in Maine and included 157 cases involving injured workers (cases) and 251 cases involving uninjured workers (controls).
This study showed that injured workers were three times less likely than uninjured workers to work in an establishment having a lockout/tagout program. Although the data from this study do not establish a direct link between injuries and the absence of lockout/tagout programs, they do suggest an association between those factors.
In addition to these analyses, commenters — including companies such as Bell Atlantic and Kodak; unions such as the UAW, USWA, and the International Brotherhood of Electrical Workers; employer groups such as the Organization Resources Counselors; and professional societies such as the American Society of Safety Engineers — stated that the standard was effective in saving lives and preventing injuries.
Most comments supported continuing the standard because it had been effective in achieving its worker protection goal. Some participants suggested that OSHA revise certain provisions of the rule they felt were complex. Most commenters urged OSHA to address the issues by providing compliance assistance materials rather than by reopening the rulemaking. Those commenters to the docket who represented small businesses, such as the National Association of Manufacturers, the Society of the Plastics Industry, and the Synthetic Organic Chemical Manufacturers Association, also generally agreed. They stated that additional compliance assistance, rather than a reopening of the rulemaking, was an appropriate way for OSHA to address these commenters’ concerns.
In response, OSHA will provide additional compliance materials. Specifically, OSHA will:
- review and update the Lockout/Tagout compliance directive, STD 1-7.3;
- review existing interpretations relating to the standard and develop interpretations to address questions raised by review participants;
- develop, in conjunction with the National Automobile Dealers Association, compliance assistance materials for industries engaged in vehicle maintenance and repair.
OSHA already has completed several documents related to the standard in response to comments made during this review. These include:
- The Lockout/Tagout Interactive Training Program, which consists of three major components: a tutorial, a group of abstracts called hot topics, and a group of interactive case studies. The tutorial explains the standard in a question/answer format. The "hot topics" consist of five abstracts containing a detailed discussion of major issues in which relevant highlighted sections of the documents are linked together. In the interactive case studies, seven simulated lockout/tagout inspections are presented.
- The Lockout/Tagout Plus Advisor, which is interactive, expert, diagnostic software. It allows users to be interviewed about their activities to determine whether workers might be exposed to hazards from moving machinery, electricity, or other sources of energy. It asks questions to determine whether the work is covered by the standard or other standards related to hazardous energy. The software responds to the users’ facts to provide expert guidance, explanations, and assistance.
[These materials, and a copy of the entire review, may be obtained from the OSHA Publications Office, Room N-2101, 200 Constitution Ave., N.W., Wash-ington, DC 20210. OSHA Web site: www.osha.gov. Direct technical inquiries about the Lockout/Tagout Standard can be sent to: Walter Siegfried, General Industry Compliance Assistance, Room N-3107. Telephone: (202) 693-1866.]
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