Often when talking to groups about the importance of having an established Lock Out / Tag Out procedure on the farm, someone invariably will point out “Hey farms are exempt from that”. While there may be a grain of truth in there, the reality is the Laws of Physics provide far more direction on how to prevent an injury on the farm than the laws of OSHA…but more on that in a moment.
When was the last time you, or someone you know, was injured while working on farm machinery or equipment because something moved when it shouldn’t have? It happens every day, multiple times a day, all over the state. It happens to guys like Derek when he was working on the auger in a grain bin, and his brother Eric walks by and wonders why the knife switch on the panel is off as he flips it on. It happens to guys like Jared when they are installing a new outlet, and Alex walks in wondering why lights are off and the switch isn’t working. He walks into the breaker room without seeing Jared and finds the breaker that someone shut off for whatever reason…
Lock Out / Tag Out (LOTO) or “Hazardous Energy Control”
As defined by OSHA is a process by which we can work on equipment and machinery safely after every energy source has been controlled. Electric and mechanical energy are the two types of energy that first come to everyone’s mind. We also need to consider other sources of energy including hydraulic, pneumatic, chemical, thermal, gravitational, and any other source of energy that could cause unintended movement resulting in injury.
When considering the energy source, we must consider what energy may be released either by turning the machine on, or what may be released turning it off. For instance, turning the electric power on will activate mechanical processes, while turning off or bleeding off hydraulic power may result in components moving as the hydraulic pressure holding them in place is reduced.
Newton’s third law of motion:
States that for every action, there is an equal and opposite reaction. In many cases simply “turning off” the power doesn’t make something safe to work on. Not only must we disconnect the power source, but we must find a way to dissipate the stored energy. Think of the spring in a pen. You can exert effort to depress the spring, but even when you stop exerting pressure to the spring it still wants to move. It still wants to return to its neutral position. That energy that wants to return the spring to its neutral position is stored energy.
How to establish a LOTO policy
- Develop a procedure for each piece of equipment. Evaluate each piece of equipment against the list of energy sources above, and determine how you can disconnect, release energy in a controlled manner, and/or interrupt the release of energy to prevent movement (Think: safety brace to prevent a dump body from lowering).
- Determine what types of control devices are needed. In many instances a simple padlock used solely by one employee is enough to lock out power.
- Applying the LOTO control devices, attempt to restart the equipment to ensure all power sources have been locked out.
- Train all affected employees on the procedures.
While farms are exempted from the LOTO standard for general industry detailed under 29 CFR 1910.147, I strongly recommend every farm use the same principles. The OSHA standard for farms only mentions disconnecting power sources of engines during servicing/maintenance in 29 CFR 1928(a)(11). As an employer however you are always subject to the OSHA general duty clause in Section 5(a)(1) which requires that each employer furnish to each of its employees a workplace that is free from recognized hazards that are causing or likely to cause death or serious physical harm. More importantly, we are all subject to the laws of physics.
I invite you to visit our collection of articles and videos at RuralMutual.com as well as check out our Youtube channel. We will be releasing a series of short (1-3 minute) videos specifically on LOTO to help provide additional direction on how to use LOTO on the farm to ensure safety.
Chris Schlechta – Rural Mutual Safety & Loss Control Manager
Check out these links for important information and updates regarding Lock Out Tag Out.
Grainger (to purchase protective devices w/ farm bureau discount): https://www.grainger.com/category/safety/lockout-tagout
Farming traditions run deep in the state of Wisconsin and farm safety is a priority for farmers. As the #1 Farm Insurance in Wisconsin, Rural Mutual has been protecting farms across the state for over 85 years. We also believe in protecting the families and children in our farming communities.