ANSI/ASSE Z244.1 (2016): Bringing the Latest Practices to Lockout/Tagout and Alternative Methods
The 2016 standard was written to be scalable to meet the needs of both large and small companies with varying levels of technology present in their machinery and processes.
- By Todd Grover
- Feb 17, 2017
Without question, the methods of protecting workers against the sudden startup of machinery have greatly evolved over the years. OSHA's 29 CFR 1910.147 regulation became law in 1989 and was heavily based on ANSI’s original Z244.1 Lockout Standard first published in 1982. Industry has come a long way since then in terms of technology and new methods, but there certainly is a long way to go.
Each year, OSHA publishes its Top 10 Most Cited Violations and, again for fiscal 2016, lockout was ranked fifth (with outcomes very similar to 2015) in terms of the particular rules that were cited and value of the citations issued. Heightened self-reporting requirements for serious injuries and fatalities are bringing more violations to OSHA’s attention, and it seems many U.S. employers just do not recognize that these types of accidents continue to occur with greater frequency and severity.
The ANSI/ASSE Z244.1 (2016) The Control of Hazardous Energy – Lockout, Tagout and Alternative Methods standard seeks to address these trends with the most significant expansion of best practice guidance since the 2003 Z244 Standard revision was issued. Working as a committee member alongside the many industry representatives, trade associations, labor groups, and subject-matter experts contributing to this latest revision has been a real privilege and a valuable experience.
Although OSHA has clarified its position on elements of the 1910.147 regulation through letters of interpretation, no definitive updates or substantial changes have been issued in the more than 25 years it has been in effect. ANSI, on the other hand, has looked closely at the advancements in technology and solutions provided by a wide range of industries and has reaffirmed or revised Z244.1 every five years to continuously improve the application of this important safety practice. This better protects people doing potentially hazardous work on machinery, equipment, or processes.
The Z244 Committee continues to agree with OSHA: Workers should be protected from injury due to unexpected equipment startup or release of potentially hazardous energy. However, the committee did not try to align fully with every historic OSHA compliance requirement. We took carefully into consideration the improvements made in safety rated technology and other advancements in energy control methods proven by experience to effectively provide protection beyond basic lockout regulatory requirements. This offers enhanced opportunities to meet the needs of technology-driven and fast-paced modern workplaces without compromising the safety of personnel working hard to keep the wheels of industry turning.
The committee has made deliberate efforts not to make major changes in recommended practice that would create completely new obligations for employers and participating personnel. Instead, we focused on addressing the right thing to do to prevent sudden startup accidents based on the current knowledge available to us. The intent has been to offer a plain-language approach that describes how a range of well proven energy control practices can be accomplished and adapted to a wide range of industries. The 2016 standard was written to be scalable to meet the needs of both large and small companies with varying levels of technology present in their machinery and processes. Important new and expanded information provided in the 2016 revision of Z244.1 covers the following sections.
Section 5—Design of Machinery
The advancement of technology and engineering options in new machinery construction has resulted in a heightened capability for it to be dependably controlled during servicing operations. This section provides guidance on roles and responsibilities of suppliers and builders to design for integral lockability, tamper resistance, and the use of control reliable safeguarding technology when applicable. Suppliers are compelled by the standard to document safety systems, provide risk assessments, and offer procedures that justify alternative methods of protection and how exposures can be minimized during routine and repetitive servicing, repair, and maintenance activities.
This results in end users being better prepared to finalize their own safe work procedures for personnel operating the equipment. Machinery builders are encouraged to use the tenets of Section 5 to enhance the value of their product offerings to customers who are looking for engineering safeguards and information to be part of their purchase considerations. End users purchasing new or modified equipment also can use the guidance in Section 5 in bid specifications to make sure equipment is designed to be readily isolated, securable, and ready to be serviced safely and efficiently.
Section 6—The Hazardous Energy Control Program
The importance of a well thought out and documented lockout program is broadened by the additional information provided in Section 6. Information on managing change for new or modified equipment in the workplace and methods of timely updating and document control are noteworthy additions. This ensures analysis is performed prior to startup to allow for proper engineering and personnel preparation. Also of benefit are new or revised operating procedures, maintenance requirements, lockout instructions, training information, and tasks that may require alternative procedures.
Section 7—Control of Hazardous Energy
This section has been expanded significantly to discuss improved hazardous energy control procedures, the identification of energy isolating devices, verification by testing of the effectiveness of de-energization, as well as new provisions for interrupting energy isolation for positioning and testing requirements. More information is also offered on protective hardware and tags, including the use of warning placards, as well as complex group lockout practices and transfer of responsibility between work shifts, including the use of transfer locks. Guidance in working with contractors is also thoroughly detailed.
Section 8—Alternative Methods
A major effort was made in this section to expand guidance beyond OSHA's limitation to tasks that are routine, repetitive, and integral to production operations. The committee recognized that there are also many maintenance, repair, or service work assignments where energy may need to be present to perform the job properly, which do not allow for the full application of isolation and lockout. We held that competent evaluation methods completed specific to the task being performed is the best method of determining the feasibility of applying lockout or justifying dependable alternative methods to lockout.
Let me reflect the Z244 Committee's position clearly. Lockout shall be used unless the user can demonstrate that a well-established alternative method will provide effective protection. In situations where the task is not well understood or risk assessed, lockout shall be the default protective measure applied to control machinery or processes. Section 8 specifies that alternative methods shall be used only after hazards have been assessed and documented through the application of a Practicability (or Justification) Study. This results in a "Go/No Go" decision as to whether a risk assessment is reasonable to perform as the next step.
With a decision to move forward, a risk assessment process is completed to determine and demonstrate that the techniques used will result in negligible risk of sudden startup. These assessments detail control measures that determine whether reliance can be placed on technically reliable safeguarding methods to engineer out hazard exposures. We consider these engineering controls potentially to be an improvement over the procedural measures provided by the behavior-reliant application of lockout techniques to significantly reduce the likelihood of human error. The new ANSI standard provides detailed guidance on if, when, and how a wide range of alternative control methods can be applied to result in equal or improved protection for people performing specific tasks.
Additionally, the new Z244.1 Standard offers more than two dozen informational Annexes that provide examples of risk assessment techniques, sample policies and lockout/tagout procedures, group lockout guidance, and inspection information. Alternative risk reduction methodology is covered in detail specific to a number of new technologies, including the Packaging, Pharmaceutical, Plastics, Printing, and Steel Industries; Semiconductor and Robotic Applications; and others challenged by the current regulatory limitations.
The ANSI Z244.1 Committee strongly believes injuries and fatalities related to unexpected startup of machinery or release of hazardous energy are preventable while recognizing that zero risk is only a theoretical possibility. Our newly revised standard provides the latest information on achieving acceptable levels of risk by knowledgeably applying conventional lockout/tagout or well-determined alternative methods to prevent these avoidable accidents from occurring.
This article originally appeared in the March 2017 issue of Occupational Health & Safety.