Lockout/Tagout the only LOTO guaranteed to make you a winner every time.
Brewery workers are surrounded by an array of machines, used in the brewing process, production, and packaging. These machines, are no different to those used in any other chemical manufacturing plant. This equipment is powered by energy sources that may present hidden safety hazards or may have mechanical features that can cause severe injuries if they were to activate while someone was servicing the device. Lockout involves bringing equipment to a stop, isolating or locking out hazardous power sources and releasing stored energy to put the machine in a zero-energy state. Employers must adhere to specific LOTO practices and procedures to protect employees from the unexpected startup of machinery and equipment (29 CFR 1910.147—The Control of Hazardous Energy, Lockout/Tagout).
Not having written LOTO procedures is one of the most cited violations by OSHA. Shutting down brewery equipment to perform maintenance or servicing without equipment specific LOTO procedures can result in equipment damage and expose employees to possible serious injuries or death. LOTO procedures need to be developed for fermentation tanks, mash tuns, kettles, and bottling lines, box sealers, and any manufacturing equipment that could cause damage or harm to employees if not entirely at a zero-energy state. The procedure must isolate all energy sources, including electrical, hot surface temperatures, gravity, air, steam, hydraulic, pressurized water, and kinetic energy. Below is an example of a LOTO written procedure.
Only qualified people can develop your procedures. Each piece of equipment must be assessed to identify all hazardous energy sources to determine what types of LOTO devices will be needed to be used to isolate the hazard. To ensure all employees understand the significance of proper lockout and energy isolation procedures you should include them in the development of the procedures. Having operators involved in the development of the lockout procedures can help in verifying and confirm the lockout procedure works. Employees can see the dangers and risks involved, and understand why it’s important to follow the procedure. If you already have LOTO procedures train your employees to follow those procedures. Make sure everyone involved understands the steps and document the training. It is essential that each LOTO procedure is tested to assure that all energy sources are isolated and secured.
There are numerous devices to be used to lock and tag out equipment. The correct device must be used to lock the valve, disconnect, breaker or switch effectively. The bottom line is you must have these procedures in place. If you cannot do them in-house yourself, reach out to a third-party safety consulting group to get you into compliance (preferably with brewery experience) before you have a mishap.
If you need more information about where to get OSHA compliance assistance contact me at the links listed below.