Compliance in Wisconsin – Lockout-Tagout

Physec Compliance Group LLC services locations in Wisconsin, and Waupaca Wisconsin is home to our headquarters!

Wisconsin has a federally run OSHA program and Physec Compliance Group LLC specializes in customizing your Lockout-Tagout procedures to not only exceed OSHA federal Lockout-Tagout regulations, but also to meet your satisfaction as the most efficient, easy to follow, and visual procedure possible. to help your workplace become compliant and visually instructive.

About the Lockout-Tagout Regulation in Wisconsin:

The State of Wisconsin is under federal OSHA jurisdiction.

The control of hazardous energy (as well as related state programs) utilizes the following

intent:

1910.147(a)(1)(i) This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy.

“Lockout-tagout exists to prevent unexpected startup of the equipment or energy to prevent injury to the employee while servicing.”

And here are top benefits that help justify investing in your

lockout-tagout program:

Reduction of workers comp claims due to accidents

•On average a fatality will cost a company over $1M in increased workers comp rates, OSHA citations, and civil lawsuits. …....$1M in fines for a LOTO fatality.

Better insurance rates

•Insurance companies may offer reduced rates or even rebates that will help offset the investment needed to establish a new program.

Improved morale

•Authorized employees who focus on doing their jobs at the best of their abilities appreciate when their company invests in programs to make their jobs not only easier, but much safer.

Public Relations (PR)

•By investing proactively, companies can help to avoid what might be a PR nightmare that can result from a horrific LOTO accident on their property. They can also announce their focus on safety with press releases that help the public understand and appreciate the efforts being made.

Equipment damage protection

•When equipment can easily cost hundreds of thousands of dollars, it’s important

to protect it from damage due to unexpected start-up while it is under maintenance.

Process continuity protection

•There are times when production value far exceeds the cost of even the most advanced lockout-tagout solution in the world. Those are the times when it makes sense to upgrade.

•When a company needs to justify the investment in LOTO, they often times need to look no further than the value of their production uptime. If an incorrect lockout-tagout process causes unnecessary downtime then it’s easy to calculate how much it’s worth to avoid that potential pitfall.

The key element to successfully conducting a full facility audit of your lockout-tagout program is to thoroughly understand exactly which equipment meets the 8-criteria set forth by 1910.147(c)(4)(i) and more importantly, which equipment does not meet the 8-criteria. OSHA requires that all equipment must meet every one of the 8-criteria otherwise it must have a machine specific lockout-tagout procedure pre-written and available for the authorized employee to utilize during a lockout-tagout process.

On average, expect that 90-95% of your equipment will require a machine-specific

procedure. The most common rule of thumb to follow – if it has more than one source

of energy (including non-lockable energy such as gravity, spring, thermal, kinetic, etc.)

then it needs a procedure.

Understanding the 8-criteria can be difficult, thus the next best step is to view an example list of commonly overlooked equipment to familiarize yourself with how certain equipment might fail to meet the 8 criteria. Each piece of equipment must meet ALL 8 criteria below or they REQUIRE a lockout-tagout procedure

(reference

90- 95%

On average, expect

that 90-95% of

your equipment

will require a

machine-specific

procedure.

1. The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees;

1. the machine or equipment has a single energy source which can be readily identified and isolated;

1. the isolation and locking out of that energy source willcompletely deenergize and deactivate the machine or equipment;

1. the machine or equipment is isolated from that energy source and locked out during servicing or maintenance;

1. a single lockout device will achieve a locked-out condition;

1. the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;

1. the servicing or maintenance does not create hazards for other employees; and

2. the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

OSHA Fines Associated with Lockout-Tagout

Complying with OSHA’s Control of Hazardous Energy policy can be difficult and the potential fines for violating the regulation can be severe. The following is an explanation of the common lockout-tagout violations an OSHA inspector may issue.

Other Than Serious

Unsafe situations with little to no chance of harming an employee and that are unlikely to produce major accidents or death are considered to be Other Than Serious. This could consist of missing labeling or damaged identification tags.

Serious Violation

Situations that have a high probability of harming an employee or possibly lead to an employee death would be considered a Serious Violation; any safety issue the employer is responsible for recognizing and correcting is also considered Serious. Missing guarding, damaged lockout devices, or improper lockout procedures are all examples of serious violations.

Serious Violations can be fined up to $70,000 per incident. Companies willing to correct the situation or less serious situations/ may be issued lower fines.

Willful Violation

When an employer knowingly disregards OSHA regulations or is aware of a safety issue and does not take corrective action, it is called a Willful Violation. Not having a lockout-tagout procedure or not correcting audit findings are some examples.

The minimum fine is $5,000 and $70,000 is no deaths occur. Criminal charges and a fine of $250,000- $500,000 will be issued for loss of life situations.

Repeated Violation

When a company is fined for a violation similar to a previous one, it is considered a Repeated Violation.

Repeated Violations cannot be issued for pending violations or violations a company is currently appealing. A fine of up to $70,000 can be charged for the violation, depending on the severity of the situations.

Failure to Abate Prior Violation

When a company fails to correct a previous violations, they can be charged with a Failure to Abate Prior Violation. A date will be given for when the violations must be corrected by. Failure to correct the situation by that date will result in fines. Fines of up to $7,000 per day can be charged.

De Minimis Violation

Minor violations of the OSHA standard that do not directly impact safety may receive a De Minimis Violation. They are not fineable or recordable acts. The OSHA inspector will typically provide a list if minor issues to the employer

Physec Compliance Group can prevent this from happening to you. Call today for your FREE consultation