New Canadian Standard for Lockout Programs Debuts at Toronto Safety Conference
by Jeff Fryman, Director, Standards Development
Robotic Industries Association Posted 03/15/2005
Preparation for the next North American Robot Safety Conference, March 21-24, 2005 is complete. Continuing the pattern of the last couple conferences, we are excited to be part of the introduction of a new Canadian industrial safety standard. This time it is the new standard for lockout programs – CSA Z460-05 Control of hazardous energy – Lockout and other methods.
Taking a cue from the new American National Standard on Lockout/Tagout; ANSI/ASSE Z244.1-2003; Control of Hazardous Energy; Lockout/Tagout and Alternative Methods, this document marks the introduction of lockout programs at the national level to Canada. Lockout programs up to this time have been the purview of the provinces.
Another recent development concerning the ANSI/ASSE Z244.1-2003 was the November, 2004, release of an interpretation letter by OSHA recognizing the updated standard. The OSHA Director of Enforcement Programs made several interesting observations in his letter which, while recognizing the value of the new consensus standard, provided some caveats as to using it in enforcement actions of 29 CFR 1910.147.
The letter states in part: ‘‘…the ANSI/ASSE Z244.1-2003 standard offers useful guidance for employers and employees attempting to control hazardous energy.’‘ The letter goes on to state that OSHA has not determined that compliance with provisions in the voluntary consensus standard ‘‘…would constitute compliance with relevant OSHA requirements.’‘ This is consistent with the differing audiences for the documents.
29 CFR 1910.147, which was freely based on the Z244.1-1982, is a regulatory standard which establishes performance requirements for a hazardous energy control program upon ‘‘employers and employees’‘. The American National Standard is a voluntary consensus standard which provides guidance on establishing effective hazardous energy control programs and talks to stakeholders identified by terms such as ‘‘manufacturer’‘ and ‘‘user’‘. This is a subtle but deliberate difference because the consensus standard is not intended to be ‘‘enforceable’‘ while an OSHA standard is.
This is an important difference also in that the consensus standard introduces requirements for machine manufacturers to be diligent in their design and construction of the ‘‘machine, equipment or process’‘ to ensure that the original design provides a safe work environment that fully addresses hazardous energy control. The machine ‘‘manufacturer’‘ is not a stakeholder that OSHA can address. And talking to the ‘‘user’‘ provides safety to anyone associated with the ‘‘machine, equipment or process’‘ not just the ‘‘employee’‘. Owners, visitors, anyone should be protected from the unexpected release of hazardous energy.
Another important difference is the introduction of ‘‘alternative’‘ or ‘‘other’‘ control methods in addition to ‘‘lockout’‘. Machinery design and automation has evolved greatly since 1982. Many modern ‘‘machines, equipment or processes’‘ require power to perform routine, repetitive and predictable tasks. If ‘‘lockout’‘ or zero energy isolation is the only safety provided to a worker to do a task that, in reality, requires power to be present, then the worker is forced to decide between not doing the task, and doing the task while potentially exposed to hazardous energy. Not the situation we want to put anyone in.
The consensus standard introduces methods to determine when alternative methods to zero energy isolation are appropriate and how they can be implemented. These other methods, based on risk assessment determinations, can employ advanced safeguarding technology to protect the worker from release of hazardous energy while maintaining necessary power to portions of the machine, equipment or process that are not being worked on.
Join us in Toronto to hear about this and many other important safety issues, especially as they apply to industrial robots. Keep it safe!