Edward Grund, Chair of the Z244 Committee, and Jeff Fryman, Z244 Committee Representative for the Robotic Industries Association, each contributed significantly to the recent revision of the Z244.1 standard, “ Control of Hazardous Energy—Lockout/Tagout and Alternative Methods.”
In this joint interview, Grund and Fryman describe the challenges they faced during the revision process, the improvements made to the Z244.1 standard and their predictions for how this revised standard will impact business, industry and safety.
What role did you each play in the revision and execution of the Z244.1 standard?
Grund: I have been a member of the Z244 Committee since 1973. I was on the original committee that produced the 1982 standard, and I was also one of the core writing task group members. I chaired the committee during this revision of Z244.1, and I continue to serve as Chair.
Fryman: I represented the Robotic Industries Association, and I led some of the small working groups that developed individual parts of the standard, notably Clauses 4 and 5.4. When the previous Vice Chair retired, I was selected to fill that position.
What challenges did you face during the revision process?
Grund: I found it challenging to revise a standard in which the original language was over 25 years old. Our group had only one member from the original committee. We also had to consider the OSHA lockout standard in all discussions even though we needed to look beyond mere compliance. The committee ploughed new ground when it addressed the issue of design, and it deserves credit for recognizing its importance as a factor in injury causation, i.e. “error-provocative design.”
Fryman: The biggest challenge may have been writing a relevant document with new ideas about the control of hazardous energy while staying within the compliance requirements of the existing, but older, Occupational Safety and Health Administration (OSHA) regulations (which were based on the previous American National Standard).
How is the revised Z244.1 standard an improvement over the previous version? What new specifications, recommendations or features does it include?
Grund: The standard was a significant overhaul of a document in which the original final language was actually prepared during the 1974-1976 period. The standard, due to administrative snafus, languished for five years before approval and publication. Almost every area of the standard was enriched by the hard work of the committee members over a three-year period.
The key areas of change are the design requirements, the use of alternative methods based on risk assessment, the hierarchy of control techniques and the guidance exhibits and annexes.
Fryman: It is a totally revamped product, so hopefully it is an improvement. A great deal of technical development and capabilities have evolved since the 1982 edition of the standard. These new technologies make the control of hazardous energy both more complex and easier to achieve. It is more complex because the traditional “zero energy state” lockout situation may not be achievable (or desirable), and it is easier because the technology offers more solutions to control hazardous energy release through new devices and circuit designs. In my opinion, the greatest offering is the information on the use of “alternative methods” to control hazardous energy. Based on the results of risk assessment, workers are afforded more protection and flexibility in performing necessary tasks on machines, equipment and processes.
How will the revised Z244.1 standard impact business and industry? How will safety improve?
Grund: Companies that are interested in moving beyond mere compliance will be able to use the standard to enhance their current practices. In addition, multinational companies can use the standard offshore as an effective guide for their international operations, particularly when local regulation is absent or weak. Only time will tell if safety (injury reduction) has improved. We do know that it is highly unlikely that the 15-year-old OSHA standard will be revised, making all future Z244 revisions that much more critical in advancing the state of the art.
Fryman: Any impact should be a positive one, but it will be slow in coming. Again, the information on alternative methods of hazardous energy control offers the greatest improvement in safety, but they will be slow in acceptance and use.
Have you seen any new areas in which the revised Z244.1 standard is applied?
Grund: Some companies are moving ahead to examine practices in which traditional lockout is not possible or in which operational requirements dictate alternative methods. The use of risk assessment methods will benefit safety in these situations.
The Z244 standard is also used in civil litigation regarding hazardous energy release incidents, and it will be valuable in the defense of certain OSHA citations before administrative law judges.
Fryman: Not specifically, however, the Canadian Standards Association (CSA) used the standard as the “seed document” for developing their new CSA Z460:2005 standard on the “Control of Hazardous Energy, Lockout and Other Methods.” This is the first introduction of such a standard in Canada at the national level, as each separate province guided previous lockout provisions.
OSHA honored your request to include a link to the Z244 Committee on its “Safety and Health Topics: Control of Hazardous Energy (Lockout/Tagout)” website. How has the committee benefited since the link was posted? What kind of response or results have you received?
Grund: Anything that expands the knowledge base by increasing access will prove valuable in the future. We continue to receive periodic input from safety practitioners, and we have gained important information from the two lockout/tagout teleconferences that the ASSE sponsored.
Fryman: I would not suggest that the committee has benefited, but rather that industry has benefited. The new standard provides appropriate guidance to those who want to control hazardous energy and to improve safety in the workplace while still complying with OSHA regulations.
How do you ensure that state and federal governments recognize the revised Z244.1 standard? Have you encountered any challenges in doing this?
Grund: I cannot be sure that this recognition will occur, but it is very likely that the agencies are aware of this standard. The ASSE communicated with California (Cal)-OSHA about the Z244.1 standard so that they would be aware during any state standards development activity. Recognition will be an evolutionary occurrence.
Fryman: Obviously, this is something that we cannot ensure, but we have made progress through the OSHA interpretation letter. State programs are obligated to be as rigorous as the federal program.
Do you believe that the revised Z244.1 standard should be recognized in other areas?
Grund: Its recognition will depend on what takes place during the next several years in the regulatory arena. The standard’s universal scope gives it a wide interest, and it is being referenced in professional articles, presentations and legal cases. The next revision during 2007-2008 will allow the committee to take it to the next level with far greater recognition and acceptance.
Fryman: I believe that the standard is valid in most industry and commercial segments. The standard addresses the control of hazardous energy, and it is not limited to whom that applies like the OSHA regulations are. We use what I call the “triplet”—Machine, Equipment and Process—to identify what requires hazardous energy control. It is intended to include the widest possible “universe” to which the standard applies.
How has the revised Z244.1 standard affected each of your respective industries?
Grund: In basic manufacturing there has always been a need to address situations where “zero-energy” thinking is not always feasible. Troubleshooting, complex advanced computer-controlled process activity and inherent hazards (molten materials) require methods that embrace the fundamental principles of hazardous energy control but achieve them through alternative methods. The annexes reveal a few of the many approaches that have been in use on a regular basis. The addition of “risk assessment” methodology is intended to add legitimacy to alternatives while reducing risk to acceptable levels.
Fryman: The robotics industry has needed the concept of alternatives to the “traditional” zero-energy-state lockout to be quantified for some time. Robot technology requires that energy be available to accomplish many tasks on the robot system. By recognizing effective alternative procedures contained in our R15.06 safety standard, the Z244.1 standard, particularly Annex J, has helped us to understand that zero-energy-state lockout is not feasible or achievable for many routine and anticipated tasks. Now there are more widely recognized alternatives for providing our workers with effective safety practices.
In which new developments, projects or research is the Z244 Committee currently involved?
Grund: The committee is gathering information during its downtime to be used as ideas for future deliberation. One project that we will attempt to launch in the near term is to have safety graduate students research lockout/tagout injury incidents that occurred between 1995 and 2005. This data will be of great value since most statistical information is quite dated.
Fryman: The group is also on a well-deserved rest after successfully guiding the standard to publication. We look forward to the next review cycle and to the opportunity to refine and to further the guidance the standard provides.
Edward Grund is a Safety Consultant with over thirty years of professional loss-prevention experience in the metal, chemical, glass, plastic and refractory industries. Grund managed prevention programs for the worldwide operations of Amax, Inc., Kaiser Aluminum and American National Can Company over a 20-year period, and throughout his career, he has been responsible for safety, fire protection, industrial security, industrial hygiene, occupational health, environmental management and workers’ compensation.
Grund is Chair of both the Z244 and Z117 Committees, and he is also a Certified Safety Professional (CSP), a Registered Professional Safety Engineer (California) and a professional member of the American Society of Safety Engineers (ASSE).
In addition, he has authored numerous articles and publications, including a National Safety Council textbook titled Lockout/Tagout—The Process of Controlling Hazardous Energy.
Grund holds a bachelor of science degree in industrial engineering management from the University of Maryland and a master of science degree in safety science from the University of Southern California. He has also completed the University of California’s (Davis) hazardous materials management program.
Jeff Fryman is the Director of Standards Development at Robotic Industries Association (RIA) in Ann Arbor, Michigan. Fryman joined the RIA staff in 1996 following his retirement from the United States Air Force. During his 21+ years as an Aircraft Maintenance Officer and Program Manager in the Air Force, he gained extensive experience in managing international programs that involved technical training, support and development.
Since joining the RIA, Fryman has helped to develop U.S. national consensus standards, such as the R15.06 Robot Safety Standard, and he has served as Secretariat to several American National Standards Institute (ANSI) and International Organization for Standardization (ISO) committees. He conducts training programs on robot safety and risk assessment, and he has also presented papers at various seminars in the U.S. and internationally. In addition, he organizes workshops on behalf of the RIA and in coordination with other agencies including the National Institute of Standards and Technology (NIST) and the Canadian Standards Association (CSA).
Fryman is Vice-Chair of the ANSI Z244 Committee on the Control of Hazardous Energy, a member of the CSA Z434 Technical Committee on Robot Safety, the CSA Z460 Technical Committee on Machinery Lockout and Hazardous Energy Control, the Underwriters Laboratories (UL) 1740 Standards Technical Panel for Robot Safety, and he is the Project Team Leader for the revision of ISO 10218, the international robot safety standard under ISO TC 184/SC 2.