Craft brewery employers must adhere to specific LOTO practices and procedures to protect employees; are you in OSHA compliance?
Lockout involves bringing equipment to a stop, isloating or locking out hazardous power sources.
Brewery workers are surrounded by an array of machines used in the brewing process, production, and packaging. These machines are no different to those used in any other chemical manufacturing plant. This equipment is powered by energy sources that may present hidden safety hazards, or may have mechanical features that can cause serious injuries if they were to activate while someone was servicing the device. Lockout involves bringing equipment to a stop, isolating or locking out hazardous power sources and releasing stored energy to put the machine in a zero-energy state. Employers must adhere to specific LOTO practices and procedures to protect employees from the unexpected startup of machinery and equipment (29 CFR 1910.147—The Control of Hazardous Energy, Lockout/Tagout).
Not having written LOTO procedures is one of the most cited violations by OSHA. Shutting down brewery equipment to perform maintenance or servicing without equipment specific LOTO procedures can result in equipment damage and expose employees to possible serious injuries or death. LOTO procedures should be developed for fermentation tanks, mash tuns, kettles, bottling lines, box sealers, and any manufacturing equipment that could cause damage or harm to employees if not completely at a zero-energy state. The procedure must isolate all energy sources, including electrical, hot surface temperatures, gravity, air, steam, hydraulic, pressurized water, and kinetic energy. Below is an example of a LOTO written procedure.
NAME: 55 gal Drunk Filler Lock Out Procedure FORM: |
SUPERSEDES NUMBER: New EFFECTIVE DATE: NEW |
APPROVED BY: Safety Committee WRITTEN BY: |
REVISED: New PAGE 1 of 4 |
Lock Out Procedure for 55 Gal Drum Filler
1. 55 Gallon Drum Filler | |
2. Equipment Required: Lock/Key, Hasp, and Tag. | ![]() |
3. Notify all affected employees that the lock out is taking place. |
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4. Turn off the equipment as during normal operations. |
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5. Go to 55 Gallon drum filler electrical panel. |
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6. Locate switches for No. 1 Cooker Drive. Turn off. |
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7. Place lock out device through all pull out/lock out clamps, attach your lock. If more than one employee is working on the equipment, then a hasp must be attached and each employees lock secured to the hasp. |
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8. Go to air supply block valve and shut off air and affix LOTO device to valve and apply lock and tag. |
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9. Test for proper lock out procedure by returning to the start up panel and pressing the start button for the machine three times. If machine does not start up it has been properly locked out. |
Re-Energizing Procedure: 55 Gallon Drum Filler
1. Check area to make sure all tools and personnel are clear and that guards have been replaced.
2. Remove your lock and tag. The first lock on must be the last removed.
3. Notify all affected employees that the equipment is being re-energized. Communicate to personnel that you are about to re-energize the machine.
4. If a lock was checked out, return it to the current shift operator or Safety Coordinator along with Key, Tag, and Hasp.
Only qualified people can develop your procedures. Each piece of equipment must be assessed to identify all hazardous energy sources to determine what types of LOTO devices will be needed to be used to isolate the hazard. To ensure all employees understand the significance of proper lockout and energy isolation procedures you should include them in the development of the procedures. Having operators involved in the development of the lockout procedures can help in verifying and confirm the lockout procedure works. They can see the dangers and risks involved, and understand why it’s important to follow the procedure. If you already have LOTO procedures, take the time to train your employees to follow those procedures. Make sure everyone involved understands the steps and document the training. It is important that each LOTO procedure is tested to assure that all energy sources are isolated and secured.
There are numerous devices to be used to lock and tag out equipment. The correct device must be used effectively lock the valve, disconnect, breaker or switch.
You must have these procedures in place. If you cannot do them yourself, reach out to a third-party safety consulting group to obtain compliance (preferably with brewery experience) before you have a mishap.
If you liked this article, you may enjoy: Brewery Safety: Focus on the Forklift.