Approved 10/27/97 REQUIREMENT F. Violation/Inadequate Procedures Off-Normal (2) Use of inadequate procedures or deviations from written procedures that result in adverse effects on performance, safety, or reliability. INTERPRETATION Where is the point in the lockout/tagout process that the lockout/tagout is considered established for reporting purposes? Intent: The point in the lockout/tagout process in which the violation or deviation results in an adverse effect on the safety of the worker is when the authorizing official (Shift Manager, Shift Supervisor, Building Custodian) authorized the work to commence. This authorization occurs after the lockout/tagout is established and verified. Additional Information: The use of inadequate lockout/tagout procedures or deviations from lockout/tagout procedures causing an effect on performance or reliability and other safety concerns should be evaluated on the basis of its actual effect or potential effect. Until the work is authorized, the problem is considered administrative and performance, safety, and reliability are not affected. Electrical verification checks or mechanical system depressurizations that identify procedural inadequacies or deviations could prevent the need for reporting if the check is procedurally required and it is performed as a part of the lockout/tagout (i.e., before work is authorized). The identification of inadequate procedures or deviations from written procedures that do not meet this threshold should still be evaluated, critiqued, and investigated, and corrective actions applied as appropriate in accordance with the requirements of good conduct of operations. |
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