August 6, 2018
Failing to train workers on the control of potentially hazardous energy can be an expensive mistake. Earlier this year, in April, OSHA issued a willful citation to a Pennsylvania paperboard manufacturer for alleged violations of 29 CFR 1910.147(c)(7)(i), the section of OSHA’s lockout/tagout standard that requires employee training so that they understand the purpose and function of the energy control program and so they acquire the knowledge and skills necessary for the safe application, usage, and removal of the energy controls.
The citation also alleged that the company failed to develop, document, and use procedures for controlling hazardous energy when employees were doing maintenance on four machines, including adjustments, cleaning, replacing parts, and clearing jams.
OSHA said the company had previously been cited for both types of violations in 2014 and 2017, and the agency’s proposed penalty for this citation was $71,135.00. The overall proposed penalty: $201,212.00.
“Several violations identified in our 2015 inspection were only partially corrected or continued,” Mark Stelmack, director of OSHA’s Wilkes-Barre Area Office, said at the time. “The employer’s continued failure to follow basic safety standards places employees at risk of serious injury or worse.”
Levels of Employee Training Preventing serious injuries is the point of the lockout/tagout standard and the training requirements in it.
After explaining why employees must be trained, as mentioned above, the standard also specifies different levels of training for the three categories of employees, saying:
Removal of Locks and Tags The standard also spells out what procedures an authorized employee must follow before he or she removes lockout or tagout devices and before energy to the machine is restored. The procedures are:
When the authorized employee who applied the lockout or tagout device is not available to remove it, the device may be removed under the direction of the employer, provided that specific procedures and training for the removal have been developed, documented, and incorporated into the employer’s energy control program, the standard states at 29 CFR 1910.147(e)(3).
But that’s not all: The employer must verify that the authorized employee who applied the device is not at the facility; must make all reasonable efforts to contact the authorized employee to inform him or her that the lockout or tagout device has been removed; and must ensure the authorized employee knows the device has been removed before he or she resumes work at the facility.
Retraining and Certification of Employees’ Training Employee retraining is covered in 1910.147(c)(7)(iii)(A).
“Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures,” it states. The following section states that additional retraining must be conducted whenever a periodic inspection reveals, or whenever the employer has reason to believe, that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.
The retraining is to “reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary,” the standard states.
At 1910.147(c)(7)(iv) is the requirements that the employer is to certify that employee training has been accomplished and is being kept up to date, and the certification must include each employee’s name and the dates of training.
Retrieved from Ohsonline.com
