Rules and Standards Related to Lockout

In 2016, the Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST) revealed that an average of four deaths and 1,000 accidents annually are related to gaps in lockout/tagout procedure during maintenance tasks.

Despites the legal obligations and the potential for simple lockout tagout procedures, lockout procedure are often not well applied.

In 2016, the CNESST published a document to explain the new regulatory requirements related to lockout procedures in Quebec (sections 188.1 to 188.13 of the RROHS).

The previous version of RROHS requirements were:

• Requirement for the equipment to be turned off
• Waiting for the full stop of the equipment
• Installing a lock for every concerned worker

The new sections in the actual version of the RROHS (188.1 to 188.13) are inspired form the CSA Z640 standard.

The sections are as follow :

• definitions
• tasks to be locked out
• requirements related to lockout and danger zone
• risk analysis
• lockout procedure elaboration
• lockout procedure content
• energy sources control steps

Section 188.1 defines lockout as “an energy control method designed to install an individually keyed lock on an energy isolating device or on any other device allowing for the control of energy such as a lockout box.”

The regulation also mentions the individually keyed lock.

The regulation has defined the “control method” as ”means a method designed to maintain a machine out of working order, such as its reoperation, the closing of an electrical circuit, the opening of a valve, the release of stored energy or the movement of a part by gravity, in such a way that the working order cannot be altered without the voluntary action of every person having access to the danger zone” (section 188.1 RROHS)

Section 188.2 identifies tasks requiring a lockout or any other method that ensures equivalent safety. These tasks include erecting, installing, adjusting, inspecting, unjamming, setting up, decommissioning, maintaining, dismantling, cleaning, servicing, refurbishing, repairing, altering or unlocking excepting :

• where work is carried out in the danger zone of a machine that has a specific control mode as defined in section 189.1;
• where a machine is unplugged within the reach and under the exclusive control of the person who uses it, where the machine has a single energy source and where there remains no residual energy after the machine is unplugged.

Section 188.3, like the previous version of the RROHS, mentions that lockout must be carried out by every person having access to the danger zone of a machine.

Section 188.4 concerns the machine risk analysis required when the lockout procedure is not applicable to ensure that the alternative method provides an equivalent safety level as the lockout method. The results of the analysis must be recorded in a written document.

According to section 188.5 a lockout procedure must be  developed and applied for each machine requiring lockout. The procedures must be easily accessible on the sites where work is carried out in written form, intelligible for consulting by every person having access to the danger zone of a machine.

Section 188.6 defines the content of the lockout procedure.

Section 188.7 explains the steps of energy control in detail.

According to section 188.8, the employer must ensure that any person having access to the danger zone of the machine is trained and informed on the health and safety risks related to the work carried out on the machine and on the preventive measures specific to the energy control method applied.

Sections 188.9 and 188.10 state that an employer or a self-employed worker must obtain written authorization from the employer who has authority over the establishment before undertaking work in the danger zone of a machine.

The employer who has authority over the establishment has the responsibility for coordination and communication.

Section 188.11 gives details about lockout material to be provided by the employer who has authority over the establishment.

Section 188.12 describes the procedure to remove a lock by the employer who has the authority over the establishment with the agreement of the person who carried out lockout,

If the agreement of the person who carried out lockout is not obtained, a written procedure must be applied. Every instance of a lock being removed must be entered in a written document.

Section 188.13 makes correspondence between work on electrical installations and lockout sections in the RROHS.

Section 186 becomes section 189.1 in the actual version of the RROHS, control devices and switches (not related to lock out).

Section 5.8 of CSA Z460-13 standard is more general about the directives when lockout is not applicable.

It mentions that when hazardous energy control methods other that lockout are applied, protective systems shall be used to ensure that device or system will stop or prevent initiation of hazardous motion or release of hazardous energy.