Is Thai OSHA law requires LOTO?

Machine Safety laws in Thailand is purely requiring "Administrative Control". May be the general industries, local business are not in a position to invest for higher quality of engineering solutions. Life is always cheaper when compare with expensive fence, fixed guard, interlock guards. It is the country's legacy of safety management mindset.

The answer is “YES”

According to Ministerial Regulation Standardize Administration, Management and Implementation of Occupational, Health, Workplace Safety regarding Machineries, Cranes, and Boilers B.E. 2564 (2012).

On the first Element- Machineries Section 1-General Item 7th- said Whereas the installation, repairment, inspection on a machine or machine safeguards is taking place, the EMPLOYER shall display signs to warn if there is going on activities. The sign shall be easy to read, and clearly visible. Also providing system, method, or devices, to prevent that machine from being operated and hang tags, signs or symbol to warn not to turn on switches, of that machine.

Although the Thai official legislation does not directly mention about LOTO which more than half of the world refers to Lock-Out-Tag-Out, it requires something similar to LOTO.

Talking about Machine Safeguarding- Thai OSHA regulation does not require more than fence, fixed guard. Inter-lock safeguarding such as limit switch, light curtain, etc. are not really mentioned by the law. Instead, the law requires employer to provide safety instruction for the workers who perform their task on a machine. The law also set requirements about hair, loose cloth, jewelry rather than mandating engineering control. However, there is a requirement to the employer who assigning workers to work with machineries that can drag their limbs into it. The law asks employers to do “Risk Assessment” which includes Hazard Identification, Risk Assessment and Risk Mitigation and Control Plans.

After all, Thai safety law regarding machine safety is not really effective. It is just all about, having it as the other countries have.

A worker, was spraying water to clean screw conveyer. Of course, it was operated. The screw was moving. She accidentally drop a cleaning pad. What happen next? She picked it up and get her wrist cut off. You know what missing. This incident occurred at a canned fruit factory in Southern of Thailand. Clearly, the female worker was working with the energized machine which the rotating screw was spinning while the cover was also opened. There was no interlock to cut out power and make her safe.

There are so many injury and fatality that caused by poor machine safety in Thailand and other countries. Here is another case. A supervisor found dead near the machine drive shaft.

The incident occurred in a factory producing plywood. No matter what he was doing or why he did that, this rotating shaft could have entangled his cloth, spined him around, broke his ribs for some time before he died without anybody knowing. This type of injury or fatality can be preventable by just putting a fixed guard around the shafts. Some might argue that he went into this part of the plant without authorization. This room is restricted for only maintenance or authorized personnel. Then the question is that can the same incident occur with the qualified personnel too? Is the door or the fence interlocked? The answer is “No”.

The man wearing green shirt was being entangled by rolling machine. He lost his two hands after fighting for life with the rollers. This incident occurred in a rubber processing plant in North-Eastern province in Thailand. The factory employed 1091 employees. Is there any emergency stop? “No”. Why? -I don’t know!. May be it is too expensive for the employer to do it.

This is only my personal opinion and you no need to agree or disagree with me. My favorite control for this kind of risk- The Low-Likelihood /High-Consequence which when it happens, you will never have a chance to bring down severity. This risk have to be controlled with higher level of risk mitigation such as -Engineering Design. It can be interlock, it can be fixed guard, interlock fixed guard instead of “Administrative Control” which not really “ALARP” at all.

I know, engineering not cheap. The man’s life is also not that cheap too.

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