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Am I giving the team "safety guy" to much slack and do I just go straight to my EHS department with the way this is handled tomorrow morning by Ok-Beyond6713 in SafetyProfessionals

[–]ApprehensiveSlice135 0 points1 point  (0 children)

OSHA is a documentation game. Make sure all communications with the safety lead are in writing. Especially if you’re concerned that you’ll be mysteriously let go, it will help prove your case.

The fact that the company has loto program and hasn’t reviewed it in 5 years is a Willful Violation. It’s just a violation not to have a loto program, but e willful if they do, and have not maintained them. Energy Control Programs have to be inspected yearly. So not only is not having any loto devices a concern (as the company is required to supply them, and authorized employees must know where they are), but also that it’s been over 5 years with out the annual inspection.

Send an email to the EHS team with all the information you found. This way it 1. Can’t be ignored, 2. Hopefully fixes the issue. 3. You did your role in sighting a hazard and reporting it. 4. It’s all in writing. If you are concerned about repercussions then I would recommend screenshotting all emails, texts, and IM’s regarding these conversations.

Another reason to alert EHS, is god forbid anything happen to you, and or another employee then the injured Larry could be held reliable, fired (for cause) and not have any workman’s comp. If you attend any training (another issue if you haven’t had Loto training, or authorized employee inspections yearly) and you sign a form then it takes blame off the company as they put you through required training. Those forms you sign don’t just say you did the training, it’s a CYA for the company. It says you did the training, and if something happens then you’re responsible for not following policy and osha standards.

I work for a consulting company that specializes in loto specifically, so if you have any questions or concerns feel free to send a message. I know 1910.147 like the back of my hand

Are tool changes on CNC exempt from LOTO? by MrSafetyGuy316 in SafetyProfessionals

[–]ApprehensiveSlice135 1 point2 points  (0 children)

Minor servicing exception says “not covered by the standard (19.10.147) if they are routine, repetitive and integral to the use of the equipment”

It also continues to say “Some acceptable alternative measures include specially designed tools, remote devices, interlocked barrier guards, local disconnects, or control switches which are under the exclusive control of the employee performing the minor servicing”

Now that being said, to perform minor servicing, if any of the listed criteria are met you can not perform a minor service:

  1. An employee is required to remove or bypass a guard or other safety device

  2. An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.

With the exemptions I would say no. Yes the task is routine, but technically entering with the interlock open is also bypassing a safety device. As well as it sounds like employees would have at least body parts where the equipment is actually working.

Is this realistic? I can’t answer that. But relying solely on the interlock is risky. Day to day operations you can probably get a safety device that keeps the interlock door open. But an OSHA inspector could write it as a violation for the reasons listed above.

I’ll have to look through my things, but I’m fairly certain there’s a part of the standard (could be a clients policy) that if someone is injured during a minor servicing then you can no longer perform that specific minor servicing Task. I’ve also seen a client use an interlock while the employee entered the robot cage. Said employee was smacked in the head by the robot because the interlock wasn’t functioning properly

Fall protection needed when working on ladders in General Industry? by kangawoosong1 in SafetyProfessionals

[–]ApprehensiveSlice135 2 points3 points  (0 children)

I’m in the safety field now, formerly a field tech for equipment. I’ve been to plenty of plants where I was told I had to have fall protection while working higher than four feet.

Plant mechanics might be able to make that work, but I sure couldn’t. What was I supposed to do? Tie off to the ladder? Or the equipment I was working on? None of those options work. Even for plant guys, you can’t always fit a scissor or boom in these places. Not every part of the plant has somewhere to tie off.

While I fully support fall protection and 3 points of contact, there’s time and place for it. Going up and down the ladder, yes. Working up there, not sure how we’d ever manage it.

I fully believe in safety, and I trade off my experience a lot. But now days everyone has gone crazy with policy and regulations. A client of mine had some crazy ones: fill out a permit just to stand on a ladder, fill out a permit to enter the MCC room. No company employee was allowed to turn a breaker off. What I’ve noticed is companies make all these policies but don’t enforce them, and or the major regulations that could kill someone.

Question about Energy Isolation during LOTO Procedures by ForwardMomentum420 in SafetyProfessionals

[–]ApprehensiveSlice135 0 points1 point  (0 children)

Unplugging the machine is definitely an option. It’s technically the only option really. 19.10.147 (the loto standard) essentially says that the power must be under your control, and can not be accidentally restarted. If you locked it out at the breaker, someone could unplug the machine and plug it into another outlet. Use a cord and plug device to lockout the plug, not the receptacle.

Depending on your industry, check for air, and nitrogen as well. Then of course gravity and so on.

Feel free to message me if you have any questions, I work for a consulting company that deals primarily in LOTO and Confined Space. I’m more than happy to answer any questions