Understanding LOTO in Indian Factories: How Do You Ensure Compliance and Safety?

Dear Seniors,

I have some queries regarding LOTO. Please comment.

1. What is the LOTO provision as per the Indian Factory Act/Rules?
2. Is there any exemption when required to work frequently during the process?
3. How to effectively check its implementation at the plant.

Thanks,
Abhay

Dear abhay girish,
This will help you:
Section 24 of Factories Act:. Striking gear and devices for cutting off power.—
(3) When a device, which can inadvertently shift from “off” to “on” position, is provided in a factory to cut off power, arrangements shall be provided for locking the device in safe position to prevent accidental starting of the transmission machinery or other machines to which the device is fitted].
(2) In every factory suitable devices for cutting off power in emergencies from running machinery shall be provided and maintained in every workroom: Provided that in respect of factories in operation before the commencement of this Act, the provisions of this sub-section shall apply only to workrooms in which electricity is used as power.

Let me try to give my inputs on this:

1. What is the LOTO provision as per Indian Factory Act/Rules?

The Factory Act and rules are silent on the requirement for LOTO in particular. Apart from what Mr. Krishan Verma pointed out, there is no clause in the entire act and rules. If you need a citation for the sake of one, that's okay. Otherwise, one can interpret the emergency stop and fuses to fulfill this particular citation.

It's a voluntary thing in India but mandatory under OSHA and other international legislations. In some states, the Factory Inspectors during their inspection reports ask to implement LOTO, then it becomes mandatory. Otherwise, it's voluntary in India.

When we talk about LOTO, Electrical Energy Isolation is the first thing that comes to mind. This is what most companies in India are doing or starting to do in the name of LOTO. They are not all concerned about other sources of energy such as Mechanical, Thermal, Hydraulic, Pneumatic, Chemical, etc. So, if you are thinking to implement or improve the LOTO system, think in a broader perspective and plan accordingly.

2. Is there any exemption when required to work frequently during the process?

Some industries have come up with a permit called Avoid Verbal Instructions (AVI) when there is a need to put LOTO very frequently to do testing jobs and all. LOTO requires some time and various levels of authorizations. AVI is something that is in written format with fewer authorizations between the work-executing agency and mainly the electrical department to isolate power. Again, this is site-specific with no regulation to monitor or govern in India.

3. How to effectively check its implementation at the plant?

1. Make a standard/procedure for LOTO.
2. Provide training to all based on the standard/procedure.
3. Provide all the resources, including locking devices.
4. Create a self-audit checklist for the same.
5. Conduct the audit based on the checklist.

Hope this helps.

In addition, according to Section 7A of the Factories Act (General duties of the occupier), it is stated that the occupier should take necessary actions such as providing information, instruction, training, supervision, maintenance, or monitoring to ensure the health and safety of all workers at work.

Therefore, no matter what precautions you take, accidents should not happen.

Short title and commencement

1. This Act may be cited as the Factories (Amendment) Act 1999 and shall come into operation on such date as the Minister may, by notification in the Gazette, appoint. 23rd November 1999.

New section 24A

5. The Factories Act is amended by inserting, immediately after section 24, the following section:

“Lock-out procedures

24A.—(1) Lock-out procedures shall be established and implemented for the inspection, cleaning, repair, or maintenance of any plant, machinery, or equipment that, if inadvertently activated or energized, is liable to cause bodily injury to any person.

(2) Every person carrying out any work described in subsection (1) shall be fully instructed on the lock-out procedures for that work before commencing that work.

(3) For the purposes of this section, “lock-out procedures” means a set of procedures —

(a) to ensure that all energy sources to the relevant plant, machinery, or equipment will be isolated, disconnected, or discharged; and

(b) to prevent any part of the plant, machinery, or equipment from being inadvertently activated or energized.”

for information and reference.....