Violation Detail
Standard Cited: 19100147 C04 II B The control of hazardous energy (lockout/tagout).
Inspection Nr: 995311.015
Citation: 02001
Citation Type: Serious
Abatement Date: 07/19/2015 2
Initial Penalty: $70,000.00
Current Penalty: $7,000.00
Issuance Date: 03/04/2015
Nr Instances: 1
Nr Exposed: 100
Related Event Code (REC):
Gravity: 10
Report ID: 0729300
Contest Date: 03/24/2015
Final Order: 08/26/2015
Emphasis:
Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
---|---|---|---|---|---|---|
Penalty | J: ALJ Decision | 08/26/2015 | $7,000.00 | 07/19/2015 | Serious | |
Penalty | C: Contested | 03/25/2015 | $70,000.00 | 03/25/2015 | Willful | |
Penalty | Z: Issued | 03/04/2015 | $70,000.00 | 03/25/2015 | Willful |
Text For Citation: 02 Item/Group: 001 Hazard:
29 CFR 1910.147(c)(4)(ii)(B): The energy control procedures did not clearly and specifically outline the steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy. a. Energy control procedures did not document specific steps for shutting down machines such as, but not limited to, in cells 3, 5, 7, 8, 9, 12, 13, 16, and 30, where machines included turret punches, shears, conveyor tables with electrical, pneumatic, and gravity as energy sources. The procedures only stated, "Shut off electric supply," and "shut off pneumatic supply," with no specific steps on how to accomplish shutting down. b. Energy control procedures did not document what machines were energized by the energy isolating device listed in the procedures, such as, but not limited to, for cells 3, 5, 7, 8, 9, 12, 13, 16, 30. The procedures listed energy sources such as "Electric" at "Location E1 through E5," and "Pneumatic" at "Location P1 through P4" for cell 8, but specific machines isolated by the energy sources were not specified. c. Blocking to control gravity was not documented on the procedures, such as, but not limited to, for the scrap tables on cells 5, 8, 9, 13. d. Each energy control procedure, such as, but not limited to, for cells 5, 7, 8, 9, 12, 13, 16, 30, labeled one electrical energy source as "Main Source", but the electrical energy did not isolate energy to the remainder of the electrical disconnects and cabinets in those cells. Electrical energy to the machines was only isolated electronically, which was not an acceptable means for energy isolation. e. Energy control procedures, such as, but not limited to, for cells 5, 7, 8, 9, 12, 13, 16, 30, labeled one pneumatic energy source as "Main Source," but each pneumatic source was individually isolated; there was no main source. f. Electrical and pneumatic energy sources were mislabeled on energy control procedures, such as, but not limited to, electrical source E6 was labeled as E5 (cell 5), pneumatic sources P1-P3 were not labeled at the cell (cell 5), electrical sources E1-E6 were labeled as "turn knobs" but all switches were operated by a handle (cell 5), electrical sources E1-E3 were labeled as "turn knobs" but all switches were operated by a handle (cell 7), electrical sources E1-E5 were labeled as "turn knobs" but switches E1, E3-E5 were operated by a handle (cells 8, 9, 12), a pneumatic valve near E1 was not labeled on the procedure for cell 9, electrical sources E1-E5 were labeled as "turn knobs" but switches E1-E3, E5 were operated by a handle (cell 13), electrical sources E1-E3 were labeled as "turn knobs" but were operated by a handle (cells 16, 30), a pneumatic valve next to electrical source E1 was not listed on the procedure (cell 30), pneumatic source P2 was mislabeled on the procedure as P1 (cell 30), other examples existed of the sources not labeled at the cell, such as the P4 valve at cell 8 which was the energy source to the scrap table where a fatal injury occurred. (Note: there was no mention on the employer's energy control procedures for locking out at the cell perimeter gate interlock switches, even though there were instances of the gate switches being used for energy isolation during maintenance, such as at cells 5, 8, 9, 13.) Abatement certification and abatement documentation is required for this violation. The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful. The abatement certification sheet is enclosed with the citation(s).