13.3 Lockout/Tagout, PPE, Hazard Communication & Excavation
Key Takeaways
- Lockout/tagout requires each authorized employee to apply their own lock, and only the person who applied a lock may remove it.
- Verification by attempting to start the equipment after isolation is a required step, not an optional one.
- Engineering controls rank above administrative controls, which rank above personal protective equipment in the hazard control hierarchy.
- Trenches five feet deep or more require a protective system, and soil is never placed within two feet of the excavation edge.
- Safety Data Sheets follow a standardized 16-section format and must be readily accessible to every employee on every shift.
13.3 Lockout/Tagout, PPE, Hazard Communication & Excavation
South Carolina operators work under SC OSHA, the state-plan occupational safety program administered by SCLLR. The standards below are the ones a water or wastewater operator encounters on a normal week.
1. The Hierarchy of Controls
Controls are applied in this order, and the exam tests the ranking:
| Level | Example in a plant |
|---|---|
| Elimination | Remove the process step entirely |
| Substitution | Convert from chlorine gas to sodium hypochlorite or UV |
| Engineering | Machine guards, floor-level ventilation, fixed gas detection, guardrails, noise enclosures |
| Administrative | Procedures, training, rotation, signage, permits |
| PPE | Respirators, gloves, goggles, hearing protection |
PPE is the LAST line of defense, not the first. If a question offers both an engineering fix and a PPE fix, the engineering control is the better answer.
2. Lockout/Tagout — Control of Hazardous Energy
LOTO protects against the unexpected energization or start-up of equipment, or the release of stored energy, during servicing and maintenance.
Forms of hazardous energy
Electrical, mechanical (rotating or spring-loaded), hydraulic, pneumatic, chemical, thermal, and gravitational (a raised gate or sludge collector).
The six-step sequence
- Prepare — identify every energy source for the equipment and notify all affected employees.
- Shut down using the normal stopping procedure.
- Isolate every energy source — open the disconnect, close and chain the valve.
- Apply locks and tags — each authorized employee applies their own lock. A group lock box is used where several trades work simultaneously.
- Release stored energy — bleed pressure, drain lines, block or lower raised components, discharge capacitors, allow hot surfaces to cool.
- VERIFY — attempt to start the equipment using the normal controls, confirm it will not run, then return the control to the off position. Test electrically with a meter proven on a known live source.
Step 6 is the one people skip and the one that kills. Verification is a required step. "I turned off the breaker" is not isolation until you have proved the equipment will not start.
The rules about locks
- One lock per authorized employee, with the employee's identification on the tag.
- Only the person who applied a lock may remove it. No exceptions for convenience, shift change, or supervisor authority.
- If a lock must be removed in the owner's absence, a documented removal procedure applies: the employer verifies the employee is not on site, makes all reasonable efforts to contact them, and informs them before they resume work.
- Tags alone are not locks. A tagout-only system is permitted only where a device cannot be locked, and it demands additional safety measures.
- Shift change requires an orderly transfer so protection is continuous — the incoming employee applies their lock before the outgoing employee removes theirs.
3. Hazard Communication
The Hazard Communication Standard, aligned with the Globally Harmonized System, gives every employee the right to know about the chemicals they work with.
The four elements
- Written hazard communication program
- Chemical inventory of every hazardous chemical on site
- Labels — GHS format with product identifier, signal word, hazard statements, precautionary statements, pictograms, and supplier information
- Safety Data Sheets, readily accessible to every employee on every shift
- Training at initial assignment and whenever a new hazard is introduced
Signal words
| Word | Meaning |
|---|---|
| DANGER | More severe hazard |
| WARNING | Less severe hazard |
The 16-section Safety Data Sheet
Sections are standardized and always in the same order. The ones operators reach for most:
| Section | Content |
|---|---|
| 1 | Identification |
| 2 | Hazard identification |
| 4 | First-aid measures |
| 5 | Fire-fighting measures |
| 6 | Accidental release measures — spill response |
| 7 | Handling and storage |
| 8 | Exposure controls and personal protection |
| 9 | Physical and chemical properties |
| 10 | Stability and reactivity — incompatibilities |
Secondary containers must be labeled. A bucket of hypochlorite drawn from a bulk tank and set down unlabeled is a violation and a genuine hazard to the next person who finds it.
4. Personal Protective Equipment
| Hazard | PPE |
|---|---|
| Chemical splash | Chemical goggles plus a face shield — safety glasses alone are inadequate for splash; apron, chemical-resistant gloves and boots |
| Airborne contaminant | Respirator selected for the specific contaminant, with fit testing, medical evaluation, and training. Air-purifying respirators are useless in oxygen-deficient or IDLH atmospheres |
| Noise above the action level | Hearing protection; blower rooms and generator rooms routinely exceed it |
| Falling objects / head strike | Hard hat |
| Fall from height | Full-body harness and lanyard; guardrails preferred as an engineering control |
| Drowning | Personal flotation device whenever working over or beside open water, basins, or wet wells |
| Biological exposure | Gloves, eye protection, no eating or drinking in process areas, rigorous handwashing, and current tetanus and hepatitis B immunization |
| Traffic | High-visibility apparel and proper work zone setup |
Glove material must match the chemical — the SDS Section 8 specifies it. Latex is not a chemical glove, and a glove that resists one chemical may dissolve in another.
5. Excavation and Trenching
Collection and distribution crews dig constantly, and trench collapse is rapidly fatal — a cubic yard of soil weighs roughly as much as a small car.
The core rules
| Rule | Requirement |
|---|---|
| Locate utilities first | Call the state one-call service before digging and hand-expose where required |
| Protective systems at 5 feet | Trenches 5 feet deep or greater require sloping, benching, shoring, or shielding (trench box) unless made entirely in stable rock. Below 5 ft, a competent person may still require protection |
| Egress within 25 feet | A ladder, ramp, or stairway within 25 lateral feet of any employee in a trench 4 feet deep or more |
| Spoil pile setback | Excavated material, equipment, and materials kept at least 2 feet back from the edge |
| Competent person inspection | Inspection daily before work, after any rainstorm, and as conditions change; authority to stop work and remove employees |
| Atmospheric testing | Required in excavations deeper than 4 feet where a hazardous atmosphere could exist — which in a sewer trench is routinely the case |
| Water accumulation | No work in accumulating water without adequate precautions; dewater and re-inspect |
| Surcharge loads | Keep vehicles and heavy equipment away from the edge; use stop logs and hand signals |
Soil classification
| Type | Character | Maximum allowable slope |
|---|---|---|
| Stable rock | Solid mineral, remains intact while exposed | Vertical |
| Type A | Cohesive, unconfined compressive strength ≥ 1.5 tsf, e.g., clay | 3/4 : 1 (53°) |
| Type B | Cohesive, 0.5 to 1.5 tsf, e.g., silt, angular gravel | 1 : 1 (45°) |
| Type C | Least stable — granular soils, submerged soil, sand, or soil with water freely seeping | 1½ : 1 (34°) |
Previously disturbed soil — which describes almost every utility trench in an existing street — is generally classified no better than Type B, and submerged or seeping soil is Type C.
6. Other Routine Hazards
| Hazard | Control |
|---|---|
| Slips, trips, and falls | The most common injury category at plants. Housekeeping, drainage, grating in good repair, handrails, non-slip surfaces |
| Machine guarding | Guards in place on every belt drive, coupling, and shaft. A guard removed for maintenance goes back on before the equipment is unlocked |
| Electrical / arc flash | Only qualified persons in energized enclosures; arc-rated PPE and boundary labeling at MCCs |
| Biological | Wastewater is a biohazard; treat every exposure route seriously |
| Heat stress | Real in South Carolina summers — hydration, shade, rest cycles, acclimatization for new workers |
| Vehicle and mobile equipment | Backing spotters, seat belts, pre-use inspection |
| Fire | Extinguishers appropriate to class, inspected; hot work permits |
During lockout/tagout, which step is most often skipped and is essential to verify isolation?
A crew member locks out a pump and leaves for the day without removing their lock. What is the correct procedure?
At what depth does a trench require a protective system such as sloping, shoring, or a trench box?
Which control ranks highest in the hierarchy of hazard controls?
Which Safety Data Sheet section should an operator consult first for spill response information?