Hazardous Energy Control
The purpose of the Dow Aero (“Company”) Hazardous Energy Control Program (“HECP”), a.k.a. Lockout & Tagout, is to prevent the injury or death of employees, contractors, and visitors by providing a set of requirements designed to prevent the unexpected release of stored energy during the servicing or repair of machinery, equipment, and tools. The program serves to:
Identifies training requirements for servicing and repair of machinery, equipment, and tooling for employees and contractors.
Establish responsibility for implementing and controlling HECP policy and procedures.
Institute a safe and positive means of shutting down machinery, equipment, and tooling.
Prohibit unauthorized personnel or remote control systems from starting while applicable machinery, equipment, and tooling are being serviced.
Require a secondary control system (tagout) when unable to verify lockout of the applicable machinery, equipment, and tooling.
Ensure that only approved locks, standardized tags, and fastening devices provided by the Company are utilized in following HECP procedures.
This program has been developed in an effort for the Company to maintain compliance with Occupational Safety and Health Administration (OSHA) Rule CFR 1910.147, Rule 29 CFR 1910.306, and Rule 29 CFR 1910.333, along with other supporting rule(s). If discrepancies exist between this policy and OSHA regulation, the regulation shall govern and Environmental Health & Safety (EHS) personnel shall be notified immediately.
Responsibilities
Environmental Health & Safety (EHS)
Develop, maintain, and implement HECP policies and procedures.
Assist affected departments in complying with HECP by serving as a source of information for regulatory and safety.
Aid in the development of training programs related to HECP, in collaboration with Quality Assurance.
Authority to halt operations that are not in compliance with HECP.
Quality Assurance
Liaison to ISO/AS auditors.
Assist Environmental Health & Safety (EHS) and affected departments in complying with HECP by serving as a source of information for regulatory and safety.
Aid in the development of training programs related to HECP, in collaboration with Environmental Health & Safety (EHS).
Authority to halt operations that are not in compliance with HECP.
Department Leads
Are responsible for developing HECP procedures for machinery, equipment, and tooling within their respective department(s) as necessary.
Confirm hazard assessments for machinery, equipment, and tooling are preformed prior to authorizing any operations to proceed.
Maintain HECP service record(s) for machinery, equipment, and tooling.
Ensure that necessary locks, tags, and other protective devices are adequately available.
Authority to halt operations that are not in compliance with HECP.
Provide authorization for Contractors to perform the services for the Company.
Supervisors and Managers
Collaborate with Department Lead in developing HECP procedures for machinery, equipment, and tooling within their respective work area(s).
Start hazard assessments for machinery, equipment, and tooling.
Ensure that necessary locks, tags, and other protective devices are available and properly used by staff.
Initiate HECP service record(s) for machinery, equipment, and tooling.
Verify and certify authorized employees are trained in servicing and following department procedures.
Authority to halt operations that are not in compliance with HECP.
Authorized Employees
Are responsible for following policies and procedures required by HECP.
Understand HECP for the machinery, equipment, and tooling they are authorized to service or repair.
Communicating activities to all affected employees, other authorized employees, and superiors.
Initiate the stoppage of operations that are not in compliance with HECP.
Affected Employees
Are responsible for reporting possible malfunctions with machinery, equipment, or tooling to an authorized employee or their superior.
Follow direction of the authorized employees regarding machinery, equipment, or tooling being serviced or repaired.
May not attempt to start-up or energize machinery, equipment, and tooling that have been locked or tagged.
Contractors
Receive authorization from Department Lead to perform the service for the Company.
Are required to follow and remain in compliance with the Company’s HECP.
Procedures
The following minimum procedures must be followed during the application of lock out/tag out controls. Department Leads are required to customize these generic procedures by establishing specific written energy isolation protocols applicable to the equipment or systems that they service.
The authorized employee or supervisor must notify people affected by a shutdown that a loss of service will occur and provide the expected start and duration of the project and a description of all systems shutdown.
Sufficient lead time should be provided to allow affected areas to prepare for shutdown.
The subject equipment or system shall be shutdown using normal operating procedures.
Following shutdown, the lockout or tagout devices are attached to each energy isolating device by the authorized employee.
Once lockout or tagout has been completed, all potentially hazardous stored or residual energy must be relieved, disconnected, restrained, and otherwise rendered safe.
Prior to starting work on the subject equipment or systems, the authorized employee shall verify that isolation and de-energization has been completed successfully.
When servicing or maintenance is performed by more than one person, trade or group, group lockout or tagout devices shall be used.
Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, lockbox or comparable mechanism when beginning work and shall remove the device when work is completed.
Once work is complete and prior to removal of the lockout or tagout devices, the work area shall be inspected to ensure that nonessential items have been removed. This will include the following steps:.
Confirm the work is completed and the inventory of tools/equipment that were used are accounted for.
Remove all towels, rags, work-aids, etc.
Replace all appropriate guards.
Sometimes a particular guard may have to be left off until the start sequence is over due to possible adjustments.
All controls should be in their safest position (i.e. no power mode).
Inspect the work area to ensure that all individuals have been safely positioned or removed from work area.
Verify lockout/tagout have been removed.
The authorized employee shall be responsible for removing their lockout/tagout.
However in cases in which the authorized employee is not available to remove a lock out device, removal may be done by the authorized employee’s supervisor or manager, but only after making all reasonable efforts to contact the authorized employee and after verifying that the equipment or system is safe. These steps include:
Verification by employer that the authorized employee who applied the divide is not in the facility.
Make reasonable efforts to advise the employee that his/her device has been removed.
Ensure that the authorized employee has this knowledge before he/she resumes work at the facility.
The authorized employee must be informed that their lock out device has been removed.
If lockout procedure extends beyond current authorized employee(s) work schedule, either:
Halt procedures and leave tag(s) until the next scheduled shift; or
Transfer responsibilities to incoming authorized employee(s) and swap tag(s).
Following the removal of lockout and tagout devices, Authorized Employees, or their superior, shall notify Affected Employees that the equipment or system will be restarted.
Specific Requirements for Types of Energy Used
Electrical
Turn off power at machine and disconnect from power source.
e.g. cords, power panels, breakers, operators station, motor circuit, relays, battery packs, limit switches and electrical interlocks.
If a machine or equipment contains capacitors, they must be drained of stored energy.
If the electrical energy is disconnected by simply unplugging the power cord, the cord must be kept under the control of the authorized employee or the plug end of the cord must be locked out or tagged out.
Press start button to see that correct systems are locked out.
Some equipment may have a motor isolating shut-off and a control isolating shut-off.
Hydraulic & Pneumatic
Shut off all energy sources (e.g. pumps and compressors).
If the pumps and compressors supply energy to more than one piece of equipment, lockout or tagout the valve supplying energy to the piece of equipment being serviced.
Stored pressure from hydraulic/pneumatic lines shall be drained/bled.
Mechanical
Lock in-position or park mechanical machinery components.
e.g. gravity activation, energy stored in springs, etc.
May use blockout or die-ram safety chain mechanisms to prevent unexpected movement.
Fluids and Gases
Identify the type of fluids/gases and use necessary personal protective equipment.
e.g. safety glasses, face shield, gloves, protective suit, respirator, etc.
Close valves to prevent flow.
Drain and bleed lines as necessary.
Confirm no residual power is left.
Determine the isolating device, then close.
Gravitational
Identify the gravitational forces in the machinery, equipment, or tooling.
e.g. crane/hoist, hand-brakes, english wheel, roller machine, etc.
Release any tension or loads.
May use chain or locking mechanisms, if available.
Ensure stored energy not present before servicing.
Thermal
Confirm machinery, equipment, or tooling is not excessively hot or cold.
e.g. welding machines, coffee pots, and other heating/cooling equipment.
Confirm no active or stored energy is present before servicing.
e.g. unplug, breakers, capacitors, hydraulic water lines, etc.
Chemical
Be familiar with substances, and their appropriate personal protective equipment requirements, that are present in the active work area.
Check the SDS/MSDS Online System for more information about substances >
Confirm area is free of hazardous materials.
Avoid combining/mixing any substances that are not permitted by the manufacture.
e.g. fuels, acids, or any other combustible materials.
Pressurized Water and Steam
Be knowledgeable of the pressure that is generated from machinery, equipment, or tooling before servicing.
Check owner/operator manual for safety instructions.
Confirm machinery, equipment, or tooling is shutoff prior to disconnecting pressure hoses and/or valves.
e.g. hydraulic lines, water hoses, etc.
Contractors/Outside Personnel
Shall be notified of the enforcement and requirement of the Company’s HECP policies and procedures.
Prohibited to restart machinery, equipment, or tooling without approval from Authorized Employee or their superiors.
Required to sign a (Contractor Work Authorization - COMING SOON) prior to performing any work for the Company.
If authorization has been previously signed for the same task, it is not necessary to sign again.
Periodic Inspections
Environmental Health & Safety (EHS)
Verify inspections are correctly being performed throughout the Company.
e.g. data retention, current training records, injury/illness reports, etc.
Initiates corrective actions as necessary.
Department Leads
Verify inspections are correctly being performed throughout the department.
e.g. data retention, current training records, injury/illness reports, etc.
Initiates corrective actions as necessary.
Supervisors and Managers
Routinely inspects the Authorized Employee while performing work following the HECP.
Initiates corrective actions as necessary.
Schedule dependent on manufacture specifications.
Authorized Employees
Performs routine inspections on equipment authorized to lockout/tagout.
e.g. forklift and aerial lift, plasma cutter table, packaging foam machine, etc.
Schedule dependent on manufacture specifications.
Training
Employees are required to complete training to gain a purpose and understanding of the Company’s HECP, along with obtain knowledge and skills required for the safe application, use, and removal of energy controls, including:
Recognize applicable hazardous energy sources;
Identify the type and magnitude of the energy available in the workplace;
Comprehend methods and means necessary for energy isolation and control; and
Transfer of lockout responsibilities.
Employees who perform activities that included the operation of machinery, equipment, and tooling identified under the HECP are also required to complete additional training:
Department
Task-Specific
Renewals for general HECP training shall be required every two (2) years, while department and task-specific renewals are required annually. Training is required upon new machinery, equipment, and tooling being introduced to the work area. Training may also be required for job reassignment, incidents, or violations.
Training records shall be documented in an employee profile within the Company’s Human Resources Information System (HRIS), currently BambooHR.
Recordkeeping
Records for the Company’s HECP shall be kept for the following length of time:
EHS Audit = TBD
Contractors = TBD
Department = TBD
Training = Three (3) years after termination of employment.