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Mark Scott, ESP Manager

ES&H Manual Lockout/Tagout Program 2013 Draft Revision. Mark Scott, ESP Manager. RSC Meeting May 9 th , 2013. Objectives. Primary. Improve the quality of written LOTO Procedures: Stricter rules for scope of work, isolation checklists, and approvals

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Mark Scott, ESP Manager

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  1. ES&H Manual Lockout/Tagout Program 2013 Draft Revision Mark Scott, ESP Manager RSC Meeting May 9th, 2013

  2. Objectives Primary • Improve the quality of written LOTO Procedures: • Stricter rules for scope of work, isolation checklists, and approvals • Improve execution of written LOTO Procedures: • Layered roles and responsibilities • Heavy emphasis on the LOTO person in charge • Adjust the LOTO training requirements to match real Lab needs: • Personnel with limited LOTO needs receive less training • Personnel with extensive LOTO needs receive more training • Net neutral training impact to the Lab

  3. Objectives Secondary • Reformat the existing PUB-3000 Chapter 18 to meet the new RPM standard style guide for the ES&H Manual • General upgrade to improve overall clarity • Incorporate a number of specific corrective actions related to LOTO incidents over the last two years • Capture the 2012 Subcontractor LOTO Permit process improvements • Align terminology to regulatory standards

  4. Working Group Lab-wide representation

  5. Timeline Full SmartSheet GANTT chart available for viewing

  6. Principles of LOTO Main Components New focus area

  7. Three Training Levels New training level: Responsible Individual (RI)

  8. Energized Work vs. LOTO • Energized Testing is OK: the equipment cannot be shut down for the work being performed (testing, alignment, calibration, troubleshooting, etc…) • All other work must be performed under LOTO • Interlock protection is NOT SUFFICIENT for deenergized work

  9. Radiological Exemption For ionizing radiation only! EXEMPT • Radiological hazards that are controlled by 10 CFR 835 are exempt from 10 CFR 851 • Includes ionizing radiation, follow the Radiation Protection Program requirements instead • Work area must be covered by the Credited Control Radiation Safety System interlocks NOT EXEMPT • Lasers and RF are not exempt from LOTO controls • Working in a hazardous beamline is subject to the requirements of the LOTO Program. • Energized work is subject to program authorization and controls • Shutdown repair work is subject to LOTO: interlocks are not sufficient

  10. Improper use of LOTO lock Locking an interlock to prevent hutch door from closing, to prevent beamline turning on, even though the beam is controlled by RPP…

  11. Missing LOTO High voltage and RF hazards not controlled by LOTO, only by interlocks

  12. Setting Thresholds • The various safety programs must communicate the hazard thresholds established by recognized standards • Example: Electrical: ≥50 VAC and ≥ 5 mA • Lasers: Class 3b and 4 • RF: ? • Machines: whenever guard is removed • Robotics: ? • The various safety programs must also communicate when LOTO is required according to the LBNL LOTO Program • Specify what type of activities can be performed energized • Specify what type of activities must be performed under LOTO

  13. Next Steps There’s plenty of time to provide input • Funnel comments, questions and concerns to me • I prefer handwritten mark-ups on printed paper, but I’ll take any format that is constructive • All edits to the draft will be reviewed and approved by the Working Group • You are welcome to participate in the Implementation Planning: • Training review • JHA revision development • Web resources development

  14. UNIVERSITY OF CALIFORNIA

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