Lock-out Tag-out does is have to be a procedure in QS or can it just be referenced

[mjones2]

You can decide to include it for document control, but realize there are more than 1 way to control documents. We don't nee to put a number on anything that doesn't move.

So if you already have something set up to control the documentation electronically then go ahead with that.

It really doesn't add any value to put form #'s on 1000 LOTO's - it doesn't make them any more accurate. I am assuming there was some type of sign off / review process for these.

To write up a work instruction just to write up a work instruction doesn't make sense to me either. Tell me how it adds value - if you think it does then go for it.

The replies so far have been a little testy - so was afraid to weigh in.

M.

 

[Doug Tropf]

OSHA 29 CFR 1910.147 requires documented LOTO procedures.

 

[rfisher]

Re: Lock-out Tag-out does is have to be a procedure in QS or can it just be reference

I would be careful to include LOTO into the QMS, if you are so inclined, because if it is part of the QMS it is fair game for the auditor.

 

[Manix]

Re: Lock-out Tag-out does is have to be a procedure in QS?

Just for those who have no idea what LOTO is (like me), then visit the following link, so you know what everyone is going on about!

http://www.osha.gov/SLTC/controlhazardousenergy/index.html

Sorry, I just didn't know what this all meant as I am quite new to it all anyway. But hey, I have just learnt something

 

[RoxaneB]

Re: Lock-out Tag-out does is have to be a procedure in QS or can it just be reference

I would be careful to include LOTO into the QMS, if you are so inclined, because if it is part of the QMS it is fair game for the auditor.

Only if you (a) are unclear in establishing the scope/boundaries of the audit up front and (b) mention it during the audit.

That being said, what's the concern here? If Lock-Out Tag-Out is an established process within the organization, follows the same standardization protocols, everyone's trained, records retained, etc. etc., let the auditor at it.

A professional auditor on an ISO 9001 audit - and presuming that the organization clearly defined the scope of the audit ahead of time - will look at the document from viewpoint of the items I mentioned the paragraph before this one. If there is a problem with the LOTO process, any finding will be written up from an ISO 9001 perspective (e.g., "The documented process does not match actual practice" or something to that degree). An ISO 9001 audit (even an ISO 14001 audit) is to determine conformance to the requirements of the standard, not compliance to the law.

 

[Randy]

Hi My name is Tim and I'm sort of new to everything, but I'll give this a shot.
My Qm/QS is done all save the lock-out tag-out procedure. My question is can I keep it as a seporate manual and just referance it in my Quality manual or due I have to Write it in as a new procedure?
Thank's Tim C Elliott :

What is your document control requirement?

Are you sure you need a documented procedure?

Here's OSHA requirement...

Energy control procedure.

1910.147(c)(4)(i)
Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locker-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

 

[SteelMaiden]

Re: Does Lock-out Tag-out have to be a procedure in QMS?

Greetings, Tim

I must have missed this when it was first posted

You are not required to have a LOTO procedure within your quality manual/QMS. If you choose to refer to it, you may; or, you can include safety if you want. If it works best for you to manage your quality and safety in one, that is what you need to do.

 

[RoxaneB]

Re: Does Lock-out Tag-out have to be a procedure in QMS?

You are not required to have a LOTO procedure within your quality manual/QMS. If you choose to refer to it, you may; or, you can include safety if you want. If it works best for you to manage your quality and safety in one, that is what you need to do.

I think you answered the best, Steel...short and sweet and actually answered Tim's question.