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Safety Management Through Analysis

NFS Safety Notices
Issue No. 96-05
December 1996

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Director, Office of Nuclear and Facility Safety

U.S. Department of Energy

Washington, DC 20585

DOE/EH-0530

Issue No. 96-05

December 1996


Lockout/Tagout Programs


Contents


Notice Summary

Lockout/tagout programs are used at Department of Energy (DOE) facilities to protect personnel from injury, protect equipment from damage, and maintain plant systems. These programs are designed to identify, isolate, and control sources of hazardous energy and material that could adversely affect personnel safety during equipment operation, maintenance, or modification.

This notice provides lockout/tagout program requirements identified in DOE Orders and the Code of Federal Regulations (CFR). These requirements have been in effect for several years (since 1990) and should already be in place at DOE facilities. For DOE nuclear activities, lockout/tagout program requirements are largely covered by the Work Processes section of the DOE Quality Assurance Rule (10 CFR 830.120) and thus could potentially be subject to Price Anderson Act enforcement actions when violations occur.

The notice also describes events in which violations of lockout/tagout programs resulted in injuries or equipment damage and adversely affected facility operations. The causes and significance of these events are described along with lessons learned.

The DOE and Occupational Safety and Health Administration (OSHA) standards cited herein, provide requirements related to lockout/tagout programs. The DOE Guide to Good Practices for Lockouts and Tagouts1 can assist DOE field offices, management and operating contractors, and integrated management contractors in the development and review of lockout/tagout programs. It is important to note that for non-nuclear activities, if conflicts are discovered between OSHA requirements and those cited by DOE Orders or the Guide referenced above, OSHA shall take precedence because the OSHA CFR is law and is applicable to DOE facilities. For nuclear activities, the DOE Quality Assurance Rule (10 CFR 830.120) takes precedence.

Applicability

This notice applies to DOE facilities that perform lockout/tagout activities. The notice should be processed as an external source of lessons-learned information as described in DOE-STD-7501-95, Development of DOE Lessons Learned Programs. 2 The Office of Nuclear and Facility Safety encourages DOE managers to examine their lockout/ tagout programs in view of this information.

Lockout/Tagout Program Requirements

A comprehensive, effective lockout/tagout program shall be developed at each DOE facility to control potentially hazardous energy. The program should consist of two distinct but related processes-the identi-fication and control of the hazard by facility management, and the communication and responsibility of the worker performing servicing or maintenance. The program should include detailed administrative procedures, personnel training, uniquely identifiable tags, and periodic inspections.3

Lockout/tagout programs should include the following elements.

  • Procedures should be developed, documented, validated, and used to control hazardous energy or material.
  • Training should be provided and documented to ensure that the purpose and function of the program are understood by all personnel and that they have the knowledge and skills required to identify proper lockout/ tagout boundaries and safely install and remove locks and tags.
  • Lockout and tagout devices should be singularly identifiable and should be used only for controlling energy and no other purpose. These devices should be durable enough to withstand the environment; standardized as to color, shape, and size; and substantial enough to prevent removal without excessive force.
  • Managers should inspect energy control procedures at least annually to ensure that procedures and lockout/tagout program requirements are being followed. Supervisors should inspect work-boundary isolation devices to verify that tagout devices are properly installed and provide the required protection.1,3,4
  • Workers should inspect installed lockout/tagouts prior to starting work on equipment that has been isolated to verify that isolation and de-energization have been accomplished.
  • The lockout/tagout program should also provide for independent verification3,5 of the removal from service and the restoration to service of safety-related and other specifically identified facility equipment.
  • Existing lockout/tagouts should be reviewed during shift turnover.

The following lockout/tagout program implementation methods are used at many DOE facilities.1

Individual-Controlled Lockout/Tagout-This method of lockout/tagout is used when workers are responsible for operation and routine maintenance of an individual piece of equipment, such as milling machines, lathes, presses, and other machines. The use of this program may or may not require specific procedures to identify and control the hazards. A procedure is not required when there is a simple system, a single energy source, no other workers are affected, and there have been no accidents involving the equipment. This method of lockout/tagout requires the individual worker to be responsible for taking all necessary actions to ensure personal safety and the safety of others during maintenance.

Centrally Controlled Lockout/Tagout -This method of lockout/tagout is generally used at DOE facilities where highly integrated systems and significant hazards require that plant activities be centrally controlled by an operations group or other group with operations knowledge. The primary characteristic of a centrally controlled lockout/tagout system is a central tagging authority, typically the operations group. To be effective, this group must be cognizant of all lockout/tagout activities, including removal from service and restoration of systems and components.

Central control of lockout/tagouts is essential at these facilities because failure to understand and consider system interfaces, interrelationships, and operability requirements when isolating and restoring safety-related systems and components could result in reduction of safety margins below acceptable limits and failure to maintain safe working boundaries.

It is important not to mix the features of these two types of programs. For example, a worker may be familiar with a piece of equipment but may not be trained on the system interfaces and interactions or understand the facility drawings or logic schemes. This lack of knowledge or experience could affect the safe operations of the facility.

Events Summary

Operating Experience Analysis and Feedback engineers reviewed the Occurrence Reporting and Processing System (ORPS) database and found 335 reports on lockout/tagout-related events. The number of reported events from the first quarter of 1994 through the second quarter of 1996 shows a decreasing trend.

Lockout/tagout events typically are conduct of operations events; specifically the failure to follow procedures. Most of these events can be classified in at least one of the following categories.

  • Inadequately defined lockout/tagout
  • Incorrectly applied lockout/tagout
  • Unauthorized lockout/tagout removal
  • Lockout/tagout removed before work completed
  • Work performed without lockout/tagout

The Defense Programs (DP) Occurrence Analysis Report for the first quarter of 1996 showed that 358 out of the 1,448 DOE-wide occurrence reports reviewed by DP staff were categorized as conduct of operations. Lockout/tagout problems accounted for 9 percent of these events.8 The DP Monthly Summary Report of ORPS for June 1996, showed that lockout/tagout events accounted for 10 percent of all conduct of operations events. The number of lockout/tagout events reported in June equaled the 12-month average of 13 events.

Inadequately Defined Lockout/Tagout

On February 5, 1996, at Savannah River, two construction workers were nearly shocked during construction of a scaffold on a crane catwalk. The workers were coiling a wire rope being used as a lifeline when the rope contacted the 480-volt bus bars on the crane. Electricians had de-energized and locked out all loads on the crane except the 110-volt receptacles, lighting, and the bus bars.9

Investigators found that the work planners insufficiently identified the scope of work for the lockout because they assumed no work would be performed above the bus bars. The electrical lockout reviewer thought the bus bars were shielded. In the pre-job briefing, workers did not specifically state that the bus bars were energized.

An adequate review of documentation by engineering, operations, maintenance supervision, or affected workers may have, revealed the deficiencies contained in the lockout.

Corrective actions included the following:

  • Revised the work package to require locking out the bus bars when installing and removing lifelines from the crane.
  • Posted crane safety instructions at the crane ladder and a Danger High Voltage sign over the bus bars.
  • Conducted safety meetings on the event and issued lessons learned.

 

Incorrectly Applied Lockout/Tagout

On March 3, 1994, at the Idaho Advanced Test Reactor, an operator locked the power supply breaker for the reactor-safety rod drive closed instead of locking it open in accordance with the tagging instructions. He hung a tag stating the breaker should be in the open position and made a log entry that the breaker was locked and tagged open.10

During normal reactor outages the breaker was routinely locked and tagged in the closed position to ensure power to the safety rods could not be interrupted. The operator's "mind set" from these previous tagouts led him to lock the breaker in the wrong position. Although a second independent verification was made, the verifier failed to identify the lockout error because of complacency or lack of rigor.

Corrective action for this event included disciplinary action for the operator and verifier who incorrectly performed the tag and lockout.

Unauthorized Lockout/Tagout Removal

On June 16, 1996, at the Yucca Mountain Site Geological Disposal, an electrician removed a tag and energized a transformer without authorization from the tagout holder. Electricians had placed the caution tagout on a distribution cutout switch for the transformer after completing the extension of a 12 kV power line.11

The electrician who cleared the tagout was unsure of the reason for the tag and did not know the owner of the tag. He failed to follow the instructions on the tag that required contacting the power dispatcher.

Corrective actions included the clarification of the lockout/tagout policy and training of affected personnel on lockouts and tagouts.

Lockout/Tagout Removed Before Work Completed

On July 31, 1996, at the Rocky Flats Environmental Technology Site, stationary operating engineers removed a lock and tag from a chilled water pump before the assigned electrician verified that the work was complete and restored the electrical wiring. After the stationary operating engineers removed the lock and tag, an electrician noticed that the electrical leads for the pump motor were not connected in the coverbox.12

The work order did not direct the craftsmen to lift leads at the pump motor cover box; they lifted them as an added precaution. However, the craftsmen did not log this fact and failed to re-land the leads before the lock and tag was cleared.

Corrective actions included the following:

  • Formulated a wire-removal policy for lifting and landing electrical wires.
  • Provided lockout/tagout training to lockout/tagout personnel.
  • Briefed all personnel on the event and issued lessons learned to other facility managers.

Work Performed Without Lockout/Tagout

On June 17, 1994, an electrician working on a 480-volt distribution panel at Oak Ridge Y-12 Plant inadvertently contacted an energized 480-volt phase conductor with a ground wire. He received serious flash burns over 13 percent of his body from the electrical arc blast.13

A Type A Investigation Board determined that the electrician was not working under a high-voltage lockout/tagout that completely isolated electrical energy to the 480-volt main distribution panel. The Board also determined that the need for the lockout/tagout was not identified in the job-planning checklist, nor was personal protective equipment or equipment for safety-related work practices defined. The Board found the requirements of 29 CFR 1910.331-33515 had not been met; the work-planning process was not effective; and the job hazard analysis was informal and undocumented.

Corrective actions included the following:

  • Revised instructions for planning electrical work to ensure that the need for lockout/tagout, hold points, and personal protective equipment are addressed.
  • Developed instructions and criteria for evaluating low-voltage electrical work to determine when high-voltage energy isolation should be considered.
  • Provided High-Energy Awareness Training to Y-12 electricians.
  • Performed written job hazard analysis for activities where "on or near" electrical work exists or could exist.
  • Took disciplinary action against personnel whose actions contributed to the accident.

 

Significance of Events

A review of the Computerized Accident/ Incident Reporting System (CAIRS) database revealed that lockout/tagout events have led to 2 deaths, 1,661 lost work days, and more than $3.5 million in property damage. The Department of Labor estimates that compliance with the lockout/tagout standards in 29 CFR 1910.147 would prevent about 120 fatalities, 28,000 serious injuries, and 32,000 minor injuries each year.14

Lessons Learned

Almost all lockout/tagout events are avoidable. Only 12 percent of lockout/tagout events reported in ORPS involved equipment or material problems. The majority occurred during normal operations (54 percent), followed by maintenance (20 percent), and construction (11 percent). Figure 1 shows the distribution of lockout/tagout events by nature of occurrence for the facility condition category.

 

Figure 1. Lockout/Tagout Events

By Nature of Occurrence

The most frequent root cause of these events was attributed to management issues (44 percent). Figure 2 shows the distribution of root causes.

Figure 2. Root Causes of

Lockout/Tagout Events

There is a common thread in lockout/tagout events: at the beginning of the lockout/ tagout process, work planning, hazards analysis, and barrier analysis were inadequately performed. In many cases, electrical and piping system drawings were not accurate, or the reviews performed were not adequate to ensure that proper boundary protection would be provided against high-energy system hazards.

Worker understanding and involvement in lockout/tagout process can also play an effective role in the prevention of lockout/tagout events. The worker is responsible to verify that the boundaries adequately isolate the hazard and no energy exists. The process of boundary isolation verification by the worker would assist in the identification of inadequate lockout/tagouts.

Personnel training is an important component of an effective lockout/tagout program. Workers often do not receive the safety information and training they need; even on jobs that involve dangerous equipment, where training is clearly essential. A Bureau of Labor Statistics survey showed that of 554 workers injured while servicing equipment, 61 percent indicated they had not been informed about lockout procedures.15 Lockout/tagout training and refresher training were the most frequently recommended corrective actions reported in ORPS. Figure 3 shows the distribution of corrective actions for lockout/tagout events.

Figure 3. Lockout/Tagout Corrective Actions

Managers must identify corrective actions that will correct the problem. They should track corrective actions through completion and review of their effectiveness in preventing recurrence of the problem.16

The process for performing lockout/tagouts should be formal and well planned. Supervisors, safety engineers, and cognizant engineers should review the process where applicable. Lockout/tagouts should be performed only by qualified personnel.

Recommendations

Development and implementation of an effective lockout/tagout program is advantageous in reducing injuries. Personnel safety should be the highest priority for all DOE operations. Managers at DOE facilities should ensure that their lockout/tagout programs include, as a minimum, the following elements and recommended practices.17

Recommended Program Elements

  • Clearly defined terms and definitions.
  • Detailed procedures that describe the logical sequence of steps necessary to establish and remove, under normal and emergency conditions, locks and tags.
  • Clear assignment of duties and responsibilities for control and release of locks and tags.
  • Extensive training and retraining on lockout/tagout procedures, forms, tags, and the process. Adequate time needs to be spent performing practical exercises so that operators and mechanics can resolve any problems or questions they have while in a training setting. The training setting should be appropriate to the knowledge and skills being acquired.
  • Disciplinary action against violators of lockout/tagout procedures, including a process for termination of repeat violators.

 

Recommended Practices

  • Permit only personnel qualified through system, interface, and facility drawing knowledge and through lockout/tagout training, to install and remove locks and tags.
  • Provide instructions on the use of as-built drawings or other current documentation in preparing lockout/ tagouts. Steps to be taken in the event these materials are not available should also be provided.
  • Ensure workers are cognizant of lockout/tagout boundaries, that workers verify these boundaries and no hazardous energy exists, and that workers remain within these boundaries during the performance of the work.
  • Verify system status before starting the task. For example, when performing electrical maintenance, the electrician takes personal responsibility for his/her own safety by verifying the component and/or circuits in close proximity are de-energized using an appropriate electrical test device before start of work.
  • General employee training should emphasize that it is the responsibility of every individual to ensure that their actions and the actions of others do not violate lockout/tagout policies and procedures. This may not prevent violations but is significant in eliminating or reducing consequences should a lockout/tagout violation occur.
  • Periodically audit active lockout/tagouts to verify they are still required and that components are locked and tagged in the correct position.
  • Strong disciplinary action for lockout/tagout violations.

When outside contractors are to perform work covered by the lockout/tagout program, facility supervisors should discuss protection requirements with the contractor and eliminate any differences in interpretation and application of the procedures. All lockout/tagout protective measures should be applied in accordance with the facility procedures. The facility manager should ensure that these procedures are understood and followed by outside contractors.1

DOE contract managers may wish to include the facility lockout/tagout program requirements in contracts.

Final Evaluation

Each year OSHA tallies the number of violations and total penalties for each of its standards to determine the most frequently cited regulations. In fiscal years 1994 and 1995, lockout/tagout citations ranked second only to hazard communication. In 1994, 5,776 violations were cited; 4,862 were cited in 1995.

A lockout/tagout program should be an integral part of a facility safety program. Employees who perform lockout/tagout operations should be trained in the safe application of locks and tags. Managers should evaluate the performance of their lockout/tagout programs to ensure they are effective in preventing personnel injury.

A Hazard and Barrier Analysis Guide, produced by the Office of Operating Experience, Analysis and Feedback provides tools for the identification, evaluation and implementation of effective barriers to protect workers from hazards.18 The guide includes a hazard-barrier matrix that shows the lockout/tagout as one of the most effective barriers. When implemented properly, the lockout/tagout provides a high probability (greater than 99 percent) of success for risk reduction.

Regulations and Guidelines

The following documents apply to lockout/tagout programs used at DOE facilities.

  • DOE 440.1 establishes the framework for an effective worker-protection program designed to reduce or prevent accidental losses, injuries, and illness. The contractor requirements of the Order require compliance with 29 CFR 1910, "Occupational Safety and Health Standards," and 1926, "Safety and Health Regulations for Construction."19
  • Section 147 of 29 CFR 1910, "Control of Hazardous Energy (Lockout/Tagout)," and DOE 5480.19, "Conduct of Operations Requirements for DOE Facilities," chapter IX, "Lockouts and Tagouts," establish the minimum requirements for the control of unexpected energizing of equipment and the release of stored energy or toxic material that could cause injury to employees. 3,4,7
  • Section 120 of 10 CFR 830, "Quality Assurance Requirements," contains requirements applicable to lockout/tagout activities for nuclear activities at DOE facilities.20

These standards focus on procedures that are necessary to provide effective control when dealing with potentially hazardous energy or toxic material sources. OSHA requirements take precedence if conflicts arise between OSHA requirements and those of DOE 5480.19 and DOE-STD-1030-96.1

References

1. DOE-STD-1030-96, Guide to Good Practices for Lockouts and Tagouts, May 1996.

2. DOE-STD-7501-95, Development of DOE Lessons Learned Programs, May 1995.

3. DOE 5480.19, Conduct of Operations Requirements for DOE Facilities, July 1990.

4. 29 CFR 1910.147, The Control of Hazardous Energy (Lockout/Tagout), January 1990.

5. DOE/EH-0502, Safety Notice on "Independent Verification and Self-Checking," September 1995.

6. DOE/EH-0298, Report of the Task Group on Electrical Safety of the Department of Energy Facilities, January 1993.

7. 29 CFR 1910.331-335, Safety-Related Work Practices, December 1990.

8. DPOAR 96-1, Defense Programs Occurrence Analysis Report, First Quarter 1996, May 1996.

9. DOE Occurrence Report SR--WSRC-RBOF-1996-0004, "Cable Contacts Energized Bus Bar During Removal," April 30, 1996.

10. DOE Occurrence Report ID--EGG-ATR-1994-0005, "Improper Danger Tagout, Verification and Actuation of 250-DC-Volt Electrical Breaker That Supplies Power to ATR Safety Rods," April 21, 1994.

11. DOE Occurrence Reports HQ--SAYM-YMSGD-1996-0005, "Lockout/Tagout Procedure Infraction," June 19, 1996, and NVOO--BNOO-NTS-1996-0010, "Electrical Safety Violation - Lockout/Tagout", June 19, 1996.

12. DOE Occurrence Report RFO--KHLL-371OPS-1996-0092, "Incorrect Removal of Installed Lockout/Tagout Prior to Verifying That Electrical Components Were Operational," July 31, 1996.

13. Type A Accident Investigation Report on the June 17, 1994, "Electrical Arc Blast at Building 9725 Resulting in an Injury at the DOE Oak Ridge Reservation," August 1994.

14. OSHA Fact Sheet No. 89-32, Control of Hazardous Energy Sources (Lockout/Tagout), June 13, 1989.

15. OSHA Fact Sheet No. 93-07, Improving Worker Protection for New Workers, July 1, 1993.

16. DOE Lessons Learned Fact Sheet, Corrective Action Development and Management, August 1996.

17. DOE/EH-0180, Safety Note on "Control of Hazardous Energy," March 1991.

18. DOE-EH-33 Letter Report (draft), "Hazard and Barrier Analysis Guide," August 30, 1996.

19. DOE 440.1, Worker Protection Management for DOE Federal and Contractor Employees, September 1995.

20. 10 CFR 830.120, Quality Assurance Requirements, March 1994.

Notices Previously Issued

  • Technical Notice 94-01, "Guidelines For Valves in Tritium Service," September 1994.
  • Safety Notice 91-1, "Criticality Safety Moderator Hazards," September 1991.
  • Safety Notice 92-1, "Criticality Safety Hazards Associated With Large Vessels," February 1992.
  • Safety Notice 92-2, "Radiation Streaming at Hot Cells," August 1992.
  • Safety Notice 92-3, "Explosion Hazards of Uranium-Zirconium Alloys," August 1992.
  • Safety Notice 92-4, "Facility Logs and Records," September 1992.
  • Safety Notice 92-5, "Discharge of Fire Water Into a Critical Mass Lab," October 1992.
  • Safety Notice 92-6, "Estimated Critical Positions (ECPs)," November 1992.
  • Safety Notice 93-1, "Fire, Explosion, and High-Pressure Hazards Associated with Drums and Containers," February 1993.
  • Safety Notice 93-02, "Control of Temporary Modifications," September 1993.
  • Safety Notice 94-01, "Contamination of Emergency Diesel Generator Fuel Supplies," July 1994.
  • Safety Notice 94-02, "High-Efficiency Particulate Air Filters," August 1994.
  • Safety Notice 94-03, "Events Involving Undetected Spread of Contamination," September 1994.
  • Safety Notice 94-04, "Uninterruptible Power Supplies," November 1994.
  • Safety Notice 95-01, "Decision Analysis Techniques," August 1995.
  • Safety Notice 95-02, "Independent Verification and Self- Checking," September 1995.
  • Safety Notice 95-03, "Lessons Learned Programs," October 1995.
  • Safety Notice 95-04, "Post-Maintenance Test Programs," December 1995.
  • Safety Notice 95-05, "Department of Transportation Non- Conformances by Vendor Shippers," December 1995.
  • Safety Notice 96-01, "Chemical Spills During Loading," April 1996.
  • Safety Notice No. 96-02, "Risk-Based Analysis of Electrical Hazard," May 1996.
  • Safety Notice No. 96-03, "Compressed Gas Cylinder Safety," June 1996.
  • Safety Notice No. 96-04, "Lightning Safety," August 1996.

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This Notice is one in a series of publications issued by the Office of Nuclear and Facility Safety to share nuclear safety information throughout the Department of Energy complex. For more information, contact Richard Trevillian, Office of Operating Experience Analysis and Feedback, Office of Nuclear and Facility Safety, U.S. Department of Energy, Washington, DC 20585, telephone (301) 903-3074. This Safety Notice should be processed as an external source of lessons-learned information as described in DOE-STD-7501-95, Development of DOE Lessons-Learned Programs.

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Safety Notices are distributed to U.S. Department of Energy Program Offices, Field Offices, and contractors who have responsibility for the operation and maintenance of nuclear and related facilities, and to other organizations involved in nuclear safety. Written requests to be added to or deleted from the distribution of Safety Notices should be sent to Richard Trevillian, Office of Operating Experience Analysis and Feedback, Office of Nuclear and Facility Safety, U.S. Department of Energy, Washington, DC 20585, telephone (301) 903-3074.

The HSS Information Center maintains a file of Safety Notices and supporting information. Copies can be obtained by contacting the Info Center, (301) 903-0449, or by writing to HSS Information Center, U.S. Department of Energy, EH-72/Suite 100, CXXI/3, Germantown, MD 20874.

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