If your workplace has machines that are powered by or store hazardous energy, federal and state safety regulations require you to have machine-specific written procedures to address those hazards. Your lockout/tagout program is an essential element to keep employees safe when working around hazardous energy, but its procedures are only effective if the instructions are well drafted and employees are trained on the protocols. A chicken-rendering facility was recently cited because its failure to have clear and specific lockout/tagout procedures tragically resulted in the death of two maintenance employees. The employees had been trying to clear a blockage in a hydraulic-powered machine, which first required them to release built-up pressure. Unfortunately, the machine-specific procedure simply instructed employees to “relieve internal pressure,” without explaining how to do so. The employees decided to relieve the pressure by gingerly removing a large, bolted flange from the machine, which exposed them to the sudden release of 2,000 pounds of pressurized air and killed two of them.
OSHA investigated and cited the employer for a serious repeat lockout/tagout violation, noting that the company had recently been cited for similar problems with its lockout/tagout procedures at two other facilities. The employer appealed the citation, arguing the employees should have waited for a supervisor to arrive or for pressure to naturally release before attempting to clear the blockage. Ultimately, the U.S. Fifth Circuit Court of Appeals upheld the citation because the machine-specific procedure gave employees permission to relieve pressure within the machine, but didn’t meet the standard of clearly and specifically outlining how to do so (Darling Ingredients, Inc. v. Occupational Safety and Health Review Commission, 5th Cir, Oct. 2023).
Tips: Your lockout/tagout program must contain machine-specific procedures for controlling hazardous energy. Those instructions should be written by someone who has physically inspected your machines and can accurately capture the specific procedures and hazards present in your workplace. Don’t use generic or vague machine-specific procedures; not only will they fail to meet the applicable safety standard, they also won’t help your employees understand how to safely de-energize hazardous machines. To understand more about how to draft clear and specific lockout/tagout procedures, review our Legal Guide, Lockout/Tagout (Hazardous Energy Control), and ask your Vigilant safety professional for advice.
