LOTO Question
For a degreaser, which is a cord and plug machine, but has heated solvent in it- would this need a documented LOTO procedure?
I say yes because there is residual energy of heat and solvent. I also think this is 3 energy sources (electrical, heat, chemical).
On the other side, they say no because there is no potential for stored or residual energy and they say the other elements apply to not document a LOTO procedure (Subpart c4)
Please let me know your thoughts.
Comments (17)
A friend shared this with me:
https://www.osha.gov/enforcement/directives/cpl-02-00-147
Has great LOTO info.
I think it would depend on the type of work being done. That said on a corded machine it’s pretty darn easy to lock it out so you may as well.
I would think so. This OSHA resource references hot liquids as an energy source: https://www.osha.gov/sites/default/files/2018-12/fy11_sh-22300-11_LOTO.pptx
It being corded best practice says to LOTO. I think it would smart to also write the procedure potentially to include that the liquid be cooled as well. Hot liquids transfer their heat to what ever they come in contact with, which could include the person performing the maintenance. I would rather have a process written that protects workers even if it isn't required by the letter of the law, than to not have a good, safe procedure.
I'm leaning toward no for LOTO, but i like the suggestion of a work procedure that requires cooling time. I'm assuming this is a self contained unit that drains and the worker can unplug and roll up the cord. If the cord is tied down and will stay hanging next to the plug then yes LOTO required.
I would say yes. I would reference the IOGP LSR Report 577. As Adam mentioned thermal energy or hot liquids can transfer being an energy source. LOTO is the best way but even just a procedure for Tagout, if your facility performs just tagouts. Here's my reference:
https://www.iogp.org/oil-and-gas-safety/construction/#1522154365408-809abf06-156c
Meant to click “yes” on the poll, but fat fingered it! 😂
Since this has multiple energy sources, it would not meet the requirement of the corded plug exception found in the 1910.147(c)(4)(i). In this scenario, you have 2 energy sources: (1) electrical energy from the power plug itself and (2) the thermal energy from the heating element/heated fluid. The chemical (solvent) would not be an energy source because “chemical energy” refers to the energy associated with chemical reactions (e.g., decomposition, synthesis, etc.), not just the presence of chemicals.
Needless to say, with a corded plug lockout device and a standardized cool down period, it’s still a pretty simple procedure.
It all depends on what work is being performed on the unit.