Mark Scott, ESP Manager

RSC MeetingMay 9th, 2013

ES&H Manual

Lockout/Tagout Program

2013 Draft Revision

Objectives

• 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

Primary

2

Objectives

• 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

Secondary

3

Working GroupLab-wide representation

4

TimelineFull SmartSheet GANTT chart available for viewing

5

Principles of LOTOMain Components

6

New focus area

Three Training LevelsNew training level: Responsible Individual (RI)

7

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

8

Radiological Exemption

• 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

For ionizing radiation only!

9

• 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

EXEMPT

NOT EXEMPT

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

10

Missing LOTOHigh voltage and RF hazards not controlled by LOTO, only by interlocks

11

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

12

Next Steps

• 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

There’s plenty of time to provide input

13

UNIVERSITY OFCALIFORNIAUNIVERSITY OFCALIFORNIA