Potential Hazards

Workers in the shipyard industry face unique conditions and complex situations that put them at greater risk for injury and/or fatality. This risk is especially true during the servicing of machinery, equipment, or systems where there is the potential for inadvertent startup or the release of hazardous energy. The complexity of these types of operations is compounded by the intricacy of the worksite; the large number of workers in the work force; the involvement of multiple employers; and the vast array of machinery equipment, and systems that employees may be servicing.

Requirements and Example Solutions

• Written program and procedures must be established and implemented to control hazardous energy through the use of lockout/tags-plus applications during the servicing of any machinery, equipment, or system in shipyard employment (29 CFR 1915.89(b)). Employers should refer to 29 CFR 1915.89(b)(1) through (b)(6) for program elements.
• Facilities must establish a hierarchy of training appropriate for each employees’ job function in the control of hazardous energy during the servicing of machinery, equipment, or systems (29 CFR 1915.89(o)). The categories, indicating the level of worker involvement in servicing, are as follows:
  • Lockout/Tags-plus Coordinator - An employee designated by the employer to coordinate and oversee all lockout and tags-plus applications on vessels or vessel sections and at landside work areas when employees are performing multiple servicing operations on the same machinery, equipment, or systems at the same time, and when employees are servicing multiple machinery, equipment, or systems on the same vessel or vessel section at the same time. The lockout/tags-plus coordinator also maintains the lockout/tags-plus log (29 CFR 1915.80(b)(15)).
  • Primary Authorized Employee – An employee designated by the employer as having responsibility for each group of authorized employees performing servicing on the same machinery, equipment, or system during a group lockout/tags-plus application (29 CFR 1915.89(k)(1)(i)). Specifically, this employee determines the safe exposure status of each authorized employee in the group with regard to the lockout/tags-plus system (29 CFR 1915.89(k)(1)(ii)); obtains approval from the lockout/tags-plus coordinator to apply and remove the lockout/tags-plus system (29 CFR 1915.89(k)(1)(iii)); and coordinates the servicing operation with the coordinator (29 CFR 1915.89(k)(1)(iv)).
  • Authorized Employee - An employee who performs one or more of the following lockout/tags-plus responsibilities: executes the lockout/tags-plus procedures; installs a lock or tags-plus system on machinery, equipment, or systems; or services any machine, equipment, or system under lockout/tags-plus application (29 CFR 1915.80(b)(3)).
  • Affected Employee - An employee who normally operates or uses the machinery, equipment, or system that is going to be serviced under lockout/tags-plus or who is working in the area where servicing is being performed under lockout/tags-plus (29 CFR 1915.80(b)(2)).
• All energy sources must be identified and isolated, and the machinery, equipment, or system rendered inoperative, before any authorized employee performs servicing (29 CFR 1915.89(c)(1)). Further, verification of deenergization and isolation of all energy sources must be initially and continuously performed by each authorized employee, or the primary authorized employee in a group lockout/tags-plus application (29 CFR 1915.89(g)(1)).
• If an energy-isolating device is capable of being locked, a lock must be used unless the use of a tags-plus system, consisting of at least one energy-isolating device with a tag affixed to it, and at least one additional safety measure, can be proven to provide full employee protection equivalent to the safety provided from the use of a lock (29 CFR 1915.89(c)(2) and (c)(4)). For additional requirements pertaining to “full-employee protection” through the use of tags-plus applications, see 29 CFR 1915.89(c)(6).
• Each lock and tag must be uniquely identified for the purpose of controlling hazardous energy and not used for any other purpose (29 CFR 1915.89(n)(2)). Locks and tags must also be:
  • Durable (29 CFR 1915.89(n)(3)(i))
  • Standardized (29 CFR 1915.89(n)(3)(ii))
  • Substantial (29 CFR 1915.89(n)(3)(iii))
  • Identifiable (29 CFR 1915.89(n)(3)(iv))
• Lockout/tags-plus coordination, including a lockout/tags-plus coordinator and a lockout/tags-plus log, is required under the following two scenarios:
  • Employees on vessels and in vessel sections are servicing multiple machinery, equipment, or systems at the same time (29 CFR 1915.89(c)(7)(i)(A)); or
  • Employees on vessels, in vessel sections, and at landside facilities are performing multiple servicing operations on the same machinery, equipment, or system at the same time (29 CFR 1915.89(c)(7)(i)(B)).

Group Lockout/Tags-plus

• During group lockout/tags-plus applications, when more than one authorized employee services the same machinery, equipment or system at the same time, responsibility is to be assigned to one primary authorized employee for each group of authorized employees performing servicing (29 CFR 1915.89(k)(1)).
• Despite designation of a primary authorized employee, each authorized employee must either:
  • Apply a personal lockout/tags-plus system (29 CFR 1915.89(k)(2)(i)); or
  • Use a an alternative procedure that affords each authorized employee an equivalent level of protection as having each authorized employee apply a personal lockout/tags-plus system (29 CFR 1915.89(k)(2)(ii)).
    • Example 1: Sign a group tag (or a group tag equivalent) before servicing is started and sign off the group tag (or the group tag equivalent) when servicing is finished (29 CFR 1915.89(k)(2)(ii)(A)).
    • Example 2: Attach a personal identification device to a group lockout device before servicing is started and remove the personal identification device when servicing is finished (29 CFR 1915.89(k)(2)(ii)(B)).

Multi-employer Worksite

• Host employers of multi-employer worksites have the overall responsibility in establishing and implementing procedures to protect all workers from hazardous energy (29 CFR 1915.89(l)(1)). Despite this responsibility, the host employer may provide the contract employer with more control over the lockout/tags-plus program so long as the equivalent or greater level of protection will be provided to both the host and contract employees (Note 1 to paragraph (l) of 29 CFR 1915.89(l)). Such an agreement must be included in the contract between both employers.
  • Host Employer Responsibilities (29 CFR 1915.89(l)(2))
    • Inform each contract employer about the content of the lockout/tags-plus program and procedures in place;
    • Instruct each contract employer to follow the lockout/tags-plus program and procedures in place; and
    • Ensure that the lockout/tags-plus coordinator knows about all servicing operations and communicates with each contract employer who performs servicing or works in an area where servicing is being conducted.
  • Contract Employer Responsibilities (29 CFR 1915.89(l)(3))
    • Follow the host employer's lockout/tags-plus program and procedures;
    • Ensure that the host employer knows about the lockout/tags-plus hazards associated with the contract employer's work and what the contract employer is doing to address these hazards; and
    • Inform the host employer of any previously unidentified lockout/tags-plus hazards that the contract employer identifies at the multi-employer worksite.

Shift or Personnel Changes

• Procedures for shift or personnel changes must be established and implemented to ensure the continuity of lockout/tags-plus protection and the orderly transfer of lockout/tags-plus systems between authorized employees when they are starting and ending their workshifts, or when personnel changes occur during a workshift (29 CFR 1915.89(m)).

Employee Training

• The employer must train each employee who is, or may be, in an area where lockout/tags-plus systems are being used so they know (29 CFR 1915.89(o)(2)):
  • The purpose and function of the employer's lockout/tags-plus program and procedures;
  • The unique identity of the locks and tags to be used in the lockout/tags-plus system, as well as the standardized color, shape or size of these devices;
  • The basic components of the tags-plus system: an energy-isolating device with a tag affixed to it and an additional safety measure;
  • The prohibition against tampering with or removing any lockout/tags-plus system; and
  • The prohibition against restarting or reenergizing any machinery, equipment, or system being serviced under a lockout/tags-plus system.
• Workers designated as an affected employee, authorized employee, or lockout/tags-plus coordinator must also receive additional training to that listed above in accord with 29 CFR 1915.89(o)(3) through (o)(5).

Employee Retraining. All workers must be retrained and records retained whenever (29 CFR 1915.89(o)(6)):

• There is a change in job assignment;
• There is a change in machinery, equipment, or systems to be serviced;
• There is a change in the lockout/tags-plus program or procedures;
• It is necessary to maintain or address inadequacies in the employee's proficiency; or
• An incident investigation or program audit indicates deviations from, and inadequacies in the lockout/tags-plus program or procedures.

Records Management. Records must be made available to employees, their representatives, and the Assistant Secretary in accordance with the procedures and time periods specified in 29 CFR 1910.1020(e)(1) and (e)(3). The below table specifies what records employers must retain and for how long. (29 CFR 1915.89(r))

For More Information

• OSHA Fact Sheet entitled, Subpart F – General Working Conditions in Shipyard Employment: Lockout/Tags-plus Coordination.

Navy Notes

• When the Navy ship's force maintains control of the machinery, equipment, or systems on a vessel and has implemented such additional measures it determines are necessary, the application of at least one additional safety measure does not apply (29 CFR 1915.89(c)(4)(ii) and (c)(6)(ii)(B)). Employers need only comply with the procedures for verification of deenergization and isolation before work commences as provided in 29 CFR 1915.89(g).
• When the Navy ship's force serves as lockout/tags-plus coordinator and removes the lockout/tags-plus systems or devices, the employer’s authorized employee must inform the lockout/tags-plus coordinator that all authorized and affected employees have been notified that lockout/tags-plus applications will be removed (29 CFR 1915.89(i)(1)).
• When the Navy ship's force serves as lockout/tags-plus coordinator and maintains control of the lockout/tags-plus systems or devices during startup, the employer’s authorized employee must inform the lockout/tags-plus coordinator that tools, materials, and non-essential employees have been removed from the work area (29 CFR 1915.89(j)(2)(i) and (j)(2)(ii)).
• When the Navy ship's force serves as lockout/tags-plus coordinator and maintains control of the lockout/tags-plus log, coordination must occur between the ship's force and the employer to ensure that applicable lockout/tags-plus procedures are followed and documented (29 CFR 1915.89(c)(7)).
• When the Navy ship's force shuts down any machinery, equipment, or system, and relieves, disconnects, restrains, or otherwise renders safe all potentially hazardous energy that is connected to the machinery, equipment, or system, the employer's authorized employee must verify that the machinery, equipment, or system being serviced has been properly shut down, isolated, and deenergized (29 CFR 1915.89(e)).
• When the Navy ship's force applies the lockout/tags-plus systems or devices, the employer's authorized employee must verify the application of the lockout/tags-plus systems or devices (29 CFR 1915.89(f)).
• When the Navy ship's force serves as the lockout/tags-plus coordinator, performs the testing, and maintains control of the lockout/tags-plus systems or devices during testing, the employer's authorized employee must acknowledge to the lockout/tags-plus coordinator that (29 CFR 1915.89(h)):
  • Personnel and tools are clear;
  • Machinery, equipment, or system being serviced are ready for testing; and
  • Verifies the reapplication of the lockout/tags-plus systems upon completion of the testing.
• When the Navy ship's force maintains control of the machinery, equipment, or systems on a vessel and prohibits the employer from applying or removing the lockout/tags-plus system or starting up the machinery, equipment, or systems being serviced, the employer’s primary authorized employee must (29 CFR 1915.89(k)(2)):
  • Verify the safe exposure status of each authorized employee, and sign a group tag (or a group tag equivalent), or performs a comparable action, before servicing begins and after deenergization.
  • Verify the safe exposure status of each authorized employee, and sign off the group tag (or the group tag equivalent), or performs a comparable action, after servicing is complete and before reenergization.
• The U.S. Navy becomes the host employer when work is directly contracted with a vendor and the Navy ship's force maintains control of the lockout/tags-plus systems or devices (29 CFR 1915.89(l)).