Using E-Stops in Lockout Procedures

Disconnect Switch with Lock, Tag, and Gang-hasp
An elec­tric­al rotary dis­con­nect­ing device handle with a typ­ic­al lock, tag, and gang-hasp.

Con­trol of haz­ard­ous energy is one of the key ways that main­ten­ance and ser­vice work­ers are pro­tec­ted while main­tain­ing indus­tri­al equip­ment. Not so long ago we only thought about ‘Lock­out’ or ‘Lockout/Tagout’ pro­ced­ures, but there is much more to pro­tect­ing these work­ers than ‘just’ lock­ing out energy sources. Inev­it­ably con­di­tions come up where safe­guards may need to be removed or tem­por­ar­ily bypassed in order to dia­gnose prob­lems or to make crit­ic­al but infre­quent adjust­ments to the equip­ment, and this is where Haz­ard­ous Energy Con­trol Pro­ced­ures, or HECP, come in.

One of the ques­tions I often get when help­ing cli­ents with devel­op­ing HECPs for their equip­ment is, “Can we use the emer­gency stop cir­cuit for lock­out?” As usu­al, there is a short answer and a long answer to that simple ques­tion!

The Short Answer

The short answer to this ques­tion is NO. Lock­out requires that sources of haz­ard­ous energy be phys­ic­ally isol­ated or blocked. Con­trol sys­tems may be able to meet parts, but not all of this require­ment. Read on if you’d like to know why.

The Long Answer

Lockout

Lock­out pro­ced­ures are now grouped with oth­er adjust­ment, dia­gnost­ic and test pro­ced­ures into what are called Haz­ard­ous Energy Con­trol Pro­ced­ures or HECP. In the USA, OSHA pub­lishes a lock­out stand­ard in 29 CFR 1910.147, and ANSI pub­lishes ANSI Z244.1.

Down­load ANSI stand­ards

In Canada, we didn’t have a stand­ard for HECP until 2005 when CSA Z460 was pub­lished, although all the Provinces and Ter­rit­or­ies have some lan­guage in their legis­la­tion that at least alludes to the need for con­trol of haz­ard­ous energy. In the Province of Ontario where I live, this require­ment shows up in Ontario Reg­u­la­tion 851, Sec­tions 42, 75 and 76.

In the EU, con­trol of haz­ard­ous energy is dealt with in ISO 14118:2000, Safety of machinery — Pre­ven­tion of unex­pec­ted start-up.

Down­load ISO Stand­ards

If you have a look at the sec­tions of the Ontario reg­u­la­tions, they don’t tell you how to per­form lock­out, and they make little men­tion of what to do with live work for troubleshoot­ing pur­poses. The US OSHA reg­u­la­tions read more like a stand­ard, but because they are in legis­la­tion they are pre­script­ive. You MUST meet this min­im­um require­ment, and you may exceed it.

Let’s look at how “lock­out” is defined in the stand­ards.

Canada (Ontario) USA (OSHA) European Uni­on
Lock­out — place­ment of a lock or tag on an energy-isol­at­ing device in accord­ance with an estab­lished pro­ced­ure, thereby indic­at­ing that the energy-isol­at­ing device is not to be oper­ated until remov­al of the lock or tag in accord­ance with an estab­lished pro­ced­ure.

CSA Z460, 2005

Lock­out. The place­ment of a lock­out device on an energy isol­at­ing device, in accord­ance with an estab­lished pro­ced­ure, ensur­ing that the energy isol­at­ing device and the equip­ment being con­trolled can­not be oper­ated until the lock­out device is removed.

Tagout. The place­ment of a tagout device on an energy isol­at­ing device, in accord­ance with an estab­lished pro­ced­ure, to indic­ate that the energy isol­at­ing device and the equip­ment being con­trolled may not be oper­ated until the tagout device is removed.

29 CFR 1910.147

2.14 lockout/tagout: The place­ment of a lock/tag on the energy isol­at­ing device in accord­ance with an estab­lished pro­ced­ure, indic­at­ing that the energy isol­at­ing device shall not be oper­ated until remov­al of the lock/tag in accord­ance with an estab­lished pro­ced­ure. (The term “lockout/tagout” allows the use of a lock­out device, a tagout device, or a com­bin­a­tion of both.)

ANSI Z244.1 – 2003

 

3.3 isol­a­tion and energy dis­sip­a­tion

pro­ced­ure which con­sists of all of the four fol­low­ing actions:

a) isol­at­ing (dis­con­nect­ing, sep­ar­at­ing) the machine (or defined parts of the machine) from all power sup­plies;

b) lock­ing (or oth­er­wise secur­ing), if neces­sary (for instance in large machines or in install­a­tions), all the isol­at­ing units in the “isol­ated” pos­i­tion;

c) dis­sip­at­ing or restrain­ing [con­tain­ing] any stored energy which may give rise to a haz­ard.

NOTE Energy con­sidered in c) above may be stored in e.g.:

  • mech­an­ic­al parts con­tinu­ing to move through iner­tia;
  • mech­an­ic­al parts liable to move by grav­ity;
  • capa­cit­ors, accu­mu­lat­ors;
  • pres­sur­ized flu­ids;
  • springs.

d) veri­fy­ing by using a safe work­ing pro­ced­ure that the actions taken accord­ing to a), b) and c) above have pro­duced the desired effect.

ISO 14118 – 2000

As you can see, the defin­i­tions are fairly sim­il­ar, although slightly dif­fer­ent terms may be used. The ISO stand­ard actu­ally provides the best guid­ance over­all in my opin­ion. Note that these excerpts are all taken from the defin­i­tions sec­tions of the rel­ev­ant doc­u­ments.

One of the big dif­fer­ences between the US and Canada is the idea of ‘tagout’ (pro­nounced TAG-out for those not famil­i­ar with the term). Tagout is identic­al to lock­out with the excep­tion of the device that is attached to the energy isol­at­ing device. Under cer­tain cir­cum­stances, the US per­mits the use of a tag without a lock to secure the energy isol­a­tion device. This is not per­mit­ted in Canada under any cir­cum­stance, and the term ‘tagout’ is not offi­cially recog­nized. In Canada, the term is often taken to mean the addi­tion of a tag to the lock­ing device,  a man­dat­ory part of the pro­ced­ure.

Use of Controls for Energy Isolation

This is where the ‘rub­ber meets the road’ – how is the source of haz­ard­ous energy isol­ated effect­ively? To under­stand the require­ments, let’s look at the defin­i­tion of an Energy Isol­at­ing Device.

Canada USA EU
Energy-isol­at­ing device — a mech­an­ic­al device that phys­ic­ally pre­vents the trans­mis­sion or release of energy, includ­ing but not lim­ited to the fol­low­ing: a manu­ally oper­ated elec­tric­al cir­cuit break­er; a dis­con­nect switch; a manu­ally oper­ated switch by which the con­duct­ors of a cir­cuit can be dis­con­nec­ted from all ungroun­ded sup­ply con­duct­ors; a line valve; a block; and oth­er devices used to block or isol­ate energy (push-but­ton select­or switches and oth­er con­trol-type devices are not energy-isol­at­ing devices).

CSA Z460, 2005

Note – Bold added for emphas­is – DN

Energy isol­at­ing device. A mech­an­ic­al device that phys­ic­ally pre­vents the trans­mis­sion or release of energy, includ­ing but not lim­ited to the fol­low­ing: A manu­ally oper­ated elec­tric­al cir­cuit break­er; a dis­con­nect switch; a manu­ally oper­ated switch by which the con­duct­ors of a cir­cuit can be dis­con­nec­ted from all ungroun­ded sup­ply con­duct­ors, and, in addi­tion, no pole can be oper­ated inde­pend­ently; a line valve; a block; and any sim­il­ar device used to block or isol­ate energy. Push but­tons, select­or switches and oth­er con­trol cir­cuit type devices are not energy isol­at­ing devices.

Note – Bold added for emphas­is – DN

Tagout device. A prom­in­ent warn­ing device, such as a tag and a means of attach­ment, which can be securely fastened to an energy isol­at­ing device in accord­ance with an estab­lished pro­ced­ure, to indic­ate that the energy isol­at­ing device and the equip­ment being con­trolled may not be oper­ated until the tagout device is removed.

29 CFR 1910.147

2.8 energy isol­at­ing device: A mech­an­ic­al device that phys­ic­ally pre­vents the trans­mis­sion or release of energy, includ­ing but not lim­ited to the fol­low­ing: a manu­ally oper­ated elec­tric­al cir­cuit break­er, a dis­con­nect switch, a manu­ally oper­ated switch by which the con­duct­ors of a cir­cuit can be dis­con­nec­ted from all ungroun­ded sup­ply con­duct­ors and, in addi­tion, no pole can be oper­ated inde­pend­ently; a line valve; a block; and any sim­il­ar device used to block or isol­ate energy.

2.20.1 tagout device: A prom­in­ent warn­ing means such as a tag and a means of attach­ment, which can be securely fastened to an energy isol­at­ing device to indic­ate that the energy isol­at­ing device and the equip­ment being con­trolled may not be oper­ated until the tagout device is removed.

ANSI Z244.1 – 2003

4.1 Isol­a­tion and energy dis­sip­a­tion

Machines shall be provided with means inten­ded for isol­a­tion and energy dis­sip­a­tion (see clause 5), espe­cially with a view to major main­ten­ance, work on power cir­cuits and decom­mis­sion­ing in accord­ance with the essen­tial safety require­ment expressed in ISO/TR 12100 – 2:1992, annex A, 1.6.3.

Note – ISO/TR 12100 – 2 was with­drawn in Oct-10 and replaced by ISO 12100 – 2010. – DN Read more on this.

5.1 Devices for isol­a­tion from power sup­plies
5.1.1
Isol­a­tion devices shall:

  • ensure a reli­able isol­a­tion (dis­con­nec­tion, sep­ar­a­tion);
  • have a reli­able mech­an­ic­al link between the manu­al con­trol and the isol­at­ing element(s);
  • be equipped with clear and unam­bigu­ous iden­ti­fic­a­tion of the state of the isol­a­tion device which cor­res­ponds to each pos­i­tion of its manu­al con­trol (actu­at­or).

NOTE 1 For elec­tric­al equip­ment, a sup­ply dis­con­nect­ing device com­ply­ing with IEC 60204 – 1:1997, 5.3 “Sup­ply dis­con­nect­ing (isol­at­ing) device” meets this require­ment.

NOTE 2 Plug and sock­et sys­tems (for elec­tric­al sup­plies), or their pneu­mat­ic, hydraul­ic or mech­an­ic­al equi­val­ents, are examples of isol­at­ing devices with which it is pos­sible to achieve a vis­ible and reli­able dis­con­tinu­ity in the power sup­ply cir­cuits.

For elec­tric­al plug/socket com­bin­a­tions, see IEC 60204 – 1:1997, 5.3.2 d).

NOTE 3 For hydraul­ic and pneu­mat­ic equip­ment, see also EN 982:1996, 5.1.6 and EN 983:1996, 5.1.6.

ISO 14118 – 2000

 

BRADY Small Plug Lockout Device
BRADY Small Plug Lock­out Device

As you can see from the above defin­i­tions, all the jur­is­dic­tions require that devices used for energy isol­a­tion are reli­able, manu­ally oper­able, mech­an­ic­al devices. While elec­tric­al con­trol sys­tems that meet high levels of design reli­ab­il­ity may meet the reli­ab­il­ity require­ments, they do not meet the require­ments for phys­ic­al, mech­an­ic­al dis­con­nec­tion of the source of haz­ard­ous energy. Oper­at­or devices are spe­cific­ally excluded from this use in Canada and the USA. Note that plug and sock­et com­bin­a­tions are per­mit­ted in all jur­is­dic­tions. Lock­out devices such as Brady 65675 Large Plug Lock­out Device, like the Brady Small Plug Lock­out Device shown here and sim­il­ar devices, can be used for this pur­pose. With some plugs, it is pos­sible to put a small lock through a hole in one of the blades or pins. In some jur­is­dic­tions, even the simple act of put­ting the plug in your back pock­et while con­duct­ing the work is suf­fi­cient.

BRADY Button Locking Device
BRADY But­ton Lock­ing Device

In addi­tion, the energy isol­a­tion device is required to be able to be locked in the off, isol­ated, or blocked pos­i­tion. There are emer­gency stop but­ton oper­at­ors that can be pur­chased with an integ­rated lock cyl­in­der, and there are some con­trol oper­at­or accessor­ies avail­able that will allow con­trol push­but­tons and select­or switches to be locked in one pos­i­tion or anoth­er, but these do not meet the require­ments of the above stand­ards. They can be used in addi­tion to an energy isol­a­tion device as part of the pro­ced­ure, but not on their own as the sole means of pre­vent­ing unex­pec­ted start-up.

Conclusions

Each machine or piece of equip­ment is required to have a HECP that is spe­cif­ic to that piece of equip­ment. ‘Glob­al’ HECP’s are sel­dom use­ful except as a tem­plate doc­u­ment. Devel­op­ment of HECPs takes some care­ful thought and a thor­ough under­stand­ing of the kinds of work that will need to be done to main­tain and ser­vice the machinery. Indi­vidu­al jur­is­dic­tions have some dif­fer­ences in the details of their reg­u­la­tions, but ulti­mately the require­ments come down to the same thing: Pro­tect­ing work­ers.

Con­trol sys­tem devices such as stop but­tons and emer­gency stop devices are not accep­ted as energy isol­at­ing devices and can­not be used for this pur­pose, although they may be used as part of the HECP shut­down pro­ced­ure lead­ing up to the phys­ic­al isol­a­tion of the haz­ard­ous energy sources.

Excel­lent stand­ards exist that cov­er devel­op­ment of these pro­ced­ures and should be ref­er­enced as spe­cif­ic HECP are developed.

5% Dis­count on All Stand­ards with code: CC2011

References

Canada

Ontario Reg­u­la­tion 851, Sec­tions 42, 75 and 76.

CSA Z460-05 (R2010) – Con­trol of haz­ard­ous energy — Lock­out and oth­er meth­ods

USA

29 CFR 1910.147The con­trol of haz­ard­ous energy (lockout/tagout).

ANSI Z244.1 – 2003 (R2008) – Con­trol of Haz­ard­ous Energy – Lockout/Tagout and Altern­at­ive Meth­ods

Down­load stand­ards

Allen-Bradley 8579
Allen-Brad­ley 8579

International

ISO 14118 2000, Safety of machinery — Pre­ven­tion of unex­pec­ted start-up

Down­load ISO Stand­ards

Series Nav­ig­a­tionBust­ing Emer­gency Stop MythsRead­er Ques­tion: Mul­tiple E-Stops and Resets

Author: Doug Nix

Doug Nix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. (http://www.complianceinsight.ca) in Kitchener, Ontario, and is Lead Author and Senior Editor of the Machinery Safety 101 blog. Doug's work includes teaching machinery risk assessment techniques privately and through Conestoga College Institute of Technology and Advanced Learning in Kitchener, Ontario, as well as providing technical services and training programs to clients related to risk assessment, industrial machinery safety, safety-related control system integration and reliability, laser safety and regulatory conformity. For more see Doug's LinkedIn profile.