Printing Our Way to Safety
Applications of 3-D Printing in Lockout/Tagout
BY PHIL CLARK AND GUIDO BENDER
Controlling hazardous energy in the workplace is of paramount importance. This sounds obvious, but when OSHA originally enacted legislation back in 1971 there was no consensus standard for lockout/tagout (LOTO)—a procedure intended to ensure that equipment can’t be started when undergoing maintenance. Elements of LOTO appeared in other regulatory standards of 29 CFR 1910 (for example, woodworking, welding, and textiles) but were plagued with inconsistencies. Even when injuries related to hazardous energy occurred and were
cited under the General Duty Clause
, they often were not enforced because control of hazardous energy was not a “recognized” hazard.

LEVERAGING TECHNOLOGY
Technology has advanced to the point where many of the barriers to achieving a full lockout condition have been eliminated. Since the formalization of the 29 CFR 1910.147
Control of Hazardous Energy
standard in 1989, there have been steady advances in both the development of generic LOTO control devices and the manufacturing industry’s willingness to engineer hazards out of the equipment. Examples of these controls include points of isolation on hazardous equipment that are designed to accommodate a lock and the physical separation of high hazard areas from low hazard areas.
And yet a large number of systems and processes remain incredibly difficult or impossible to confidently render inoperable with physical locks. OSHA accommodates these challenges by allowing workers to “tagout” pieces of equipment as long as they achieve an “equivalent” level of protection. But equivalent protection is a misnomer—it is exceptionally difficult to convince a safety professional or compliance officer that a tag can achieve the same level of protection as a lock. The foremost desire of safety and health professionals is to find a way to lock out equipment to isolate the hazard.
LOCKOUT VS TAGOUT
At the National Renewable Energy Laboratory’s (NREL) Energy Systems Integration Facility (ESIF), researchers in the Fuel Cell Development and Testing Laboratory (FCDTL) test and advance hydrogen fuel cell and electrolysis technologies for numerous applications. Hydrogen fuel cell devices are tested for durability, longevity, and contamination performance on dedicated equipment that is plumbed with a variety of gas lines (for example, hydrogen, carbon monoxide, oxygen), all of which may need to be isolated and rendered inoperable during equipment service and maintenance. While these gas lines were plumbed into the lab with impressive space-conscious precision, the valves were clustered together so tightly that generic lockout/tagout devices could not fit around the closed valves (see Figure 1).
DEPARTMENTS
SAFETY
PHIL CLARK, MS, CIH,
is a point of contact for environment, safety, and health at the National Renewable Energy Laboratory’s Energy Systems Integration Facility in Golden, Colo. He can be reached at (303) 384-7240 or
phil.clark@nrel.gov
.

GUIDO BENDER,
Dr Ing
, is a senior scientist at the National Renewable Energy Laboratory. He manages the Fuel Cell Development and Testing Laboratory and is involved in many aspects of hydrogen fuel cell and water electrolysis research and development. He can be reached at (303) 275-3810 or
guido.bender@nrel.gov
.
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