Protecting Workers Performing Machine Maintenance: Comparing Modalities

Abstract Machine maintenance brings humans into exposure to hazards in unique ways. Modalities to reduce risk vary globally. In the United States the government attempts to protect workers performing maintenance via regulations imposed on employers. The relevant regulation for general industry is titled “The control of hazardous energy (lockout/tagout)”, also known as Lockout/Tagout or LOTO. LOTO relies on training of and compliance by the employees, and enforcement of the LOTO program by the employers. The cost of compliance in time spent can be high and therefore LOTO is sometimes not complied with. The European Union has a machine directive specifying safety requirements for industrial machines to meet before those machines can be sold. There is no EU regulatory requirement for LOTO like that used in the US. Some maintenance tasks that are legally allowed in Europe without LOTO would be a violation in the US. Whereas in Europe workers can be protected via alternative methods while performing some maintenance tasks, that same maintenance procedure would have to be performed under LOTO in the US to comply with regulations. Even under the LOTO standard, given the high cost of compliance in some instances, it is reasonably foreseeable to machine designers that LOTO may not be followed. The addition of alternative means of protection through machine design can enhance machine safety whether LOTO is followed. This paper will explore LOTO and alternative means of protection, compare LOTO and the use of alternative methods, identify strengths and weaknesses of both, and consider case studies regarding LOTO.