Risky Business: Lockout for Safety
Risky Business: Lockout for Safety
There’s activity around the country right now with OSHA inspections of dental laboratories. In some cases the inspection is a result of a random inspection in which OSHA determines who to inspect and in other cases, it’s a complaint by an employee or former employee. Whatever the case, if you’re the subject of the inspection, you certainly want to be ready and lockout/tagout is a critical component of your safety program.
This program still seems to be a mystery to some laboratory owners. Remember that even if you don’t have your own personnel repairing equipment that would require lockout, you must ensure that an outside contractor has a program in place to protect its workers while on your premises.
Back in July 2005, I wrote about this subject in JDT and explained the components of a lockout program. Hopefully those of you who were readers at that time developed your program. The basic requirements are as follows:
- Review and comply with OSHA’s 29 CFR 1910.147, The Control of Hazardous Energy standard and the provisions of OSHA's Electrical Safety-Related Work Practices Standards: 29 CFR 1910.331; 1910.332; 1910.333; 1910.334; and 1910.335.
- Identify the equipment that would require lockout
- Document your lockout/tagout program, including
- A list of all of the equipment included in your program.
- Detailed procedures for employees to follow when de-energizing each piece of this equipment.
- A list of who is authorized to perform these functions.
- Write procedures for locking out all equipment that requires lockout during maintenance and repair.
- Train workers who are responsible for lockout procedures and re-train them annually so they know how to safely carry out these duties, including an observation of them performing the steps.
- Train all workers in the laboratory who would be affected by a lockout procedure so they are aware of the terminology and general knowledge about your lockout/tagout program.
You can start with a list of all of the equipment in the program. Equipment that has multiple energy sources or that is connected to a remote power source must be in your program. Typical equipment in the dental laboratory that would require lockout could include:
- Burnout ovens (stored energy in the form of heat and electricity)
- Exhaust hood(s) that are direct wired to a circuit breaker panel
- Steamers (stored energy in the form of heat and electricity)
- Duplicating machines (stored energy and power source)
- Compressors that are direct wired to a circuit breaker panel
- Central suction/vacuum systems that are direct wired to a circuit breaker panel
- Casting machine (stored energy and power source)
- Boil-out tank (stored energy and power source)
- Laser welder (stored energy and power source)
- Workbenches
- HVAC
- After you’ve identified the equipment, then you must write procedures that include at a minimum the following information:
- Name of equipment
- Location in the laboratory
- Type and magnitude of energy
- Lockout device(s) used and placement
- Stored energy:, specifically how to release stored energy and verify release
- Annual audit (initial and add any notes)
Don’t forget that equipment maintenance is required under FDA’s quality system regulation and under DAMAS specifications so lockout/tagout procedures can be included in your written work instructions and standard operating procedures.
A picture is worth a thousand words, so you may want to include photos such as the ones Scott Udell of Udell Dental Lab in Minnesota has to depict the equipment and the lockout devices used. Scott has done a great job of documenting his lockout/tagout program, both in his safety program and in his quality system.
The training provided to workers who are responsible for lockout/tagout must occur each year. Some of the items that SafeLink has included on its training checklist are:
- The recognition of hazardous energy sources.
- The type and magnitude of energy sources.
- The methods used for energy control.
- The limitations of danger tags and the reasons why.
Safety of your workers during maintenance and repair of equipment mustn’t be taken lightly so ensure that this safety issue is a part of your safety program.
Go to OSHA’s Web site to obtain additional information about lockout/tagout at: http://www.osha.gov/dts/osta/lototraining/index.html; http://www.osha.gov/SLTC/controlhazardousenergy/index.html; http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&....
