OSHA has issued a directive effective July 8 and continuing until Sept. 30, telling its regional administrators and enforcement personnel how to carry out an extended National Emphasis Program for process safety management–that is, control of highly hazardous chemicals at or above the threshold quantities in the PSM standard.

Top five OSHA-cited sections of lockout/tagout standard

Employers are often surprised to learn that the most frequently OSHA cited lockout/tagout violations have little to do with the actual protective devices. The top five sections are:

  • Failure to develop, document and utilize procedures
  • Failure to establish and implement a written program
  • Failure to conduct a periodic inspection of the energy control procedure
  • Failure to provide training as described by OSHA
  • Failure to clearly outline the scope and rules to be utilized and the means
  • to enforce compliance

To ensure compliance: begin with a written lockout policy that describes your program as well as specific procedures for all machinery and equipment that requires lockout/tagout: Document audit of all machinery and equipment for types and magnitudes of energy and potential hazards; identify and document all machinery and equipment for which a lockout/tagout procedure must be developed; describe and document types and locations of energy isolating devices for all machinery and equipment; describe and document the types of energy involved and the methods to be used to dissipate or restrain the energy for all machinery and equipment; describe and document the method established to isolate the energy (lock or tag) and any additional safety measures to be taken.

Identify and document, by name and by job title, all affected employees. Identify and document, by name and by job title, all employees authorized to perform lockout/tagout procedures.

OSHA requires that employers train employees on lockout/tagout and provide proof of training. Three types of employees are covered by the standard: authorized, affected, and other. The amount and type of training that employees receive depends on their job in relation to the machine that is being locked out or tagged out.

Furthermore a periodic inspection (at least annually) must be conducted of the energy control procedure and documented. A third party or a qualified employee, other than the person who wrote the procedures, best does this.

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OSHA EXTENDS PSM NATIONAL EMPHASIS PROGRAM was last modified: August 26th, 2014 by Sarah McGorry