Most, if not all, of lockout/tagout incidents are preventable with proper compliance with OSHA's regulations, right? Wrong! It takes more than having a program in place that is compliant with OSHA's regulations to avoid these accidents. It takes employee acceptance and involvement before the catalyst of change takes place.
A company may have a preeminent safety program, but without employee involvement in the safety program creation, implementation and improvement, those employees are no more protected than if there was no safety program in place. Because lockout/tagout is the No. 1 most cited regulation in the manufacturing industry and the No. 5 most cited regulation for all industries, it only makes sense that a large portion of workplace accidents could be avoided with a solid lockout/tagout program and safety-oriented company culture.
A solid lockout/tagout program will consist of three major components:
Annual training and audits — All affected and authorized employees must be trained annually in addition to auditing the following: the employee's use of lockout/tagout (this can be done on a sampling basis) and auditing the machine specific procedures (every procedure must be audited annually with only a slight exception for equipment that is similar in nature).
Machine-specific lockout/tagout procedures — This perhaps is the most important and difficult component to comply with for most companies.
Corporate policy — The policy must include the employer's stance on how the lockout/tagout regulations specifically apply to that workplace.
WHY COMPLY?
There are numerous reasons to seek compliance, but one of the most common reasons is to avoid OSHA fines. Just recently, a bottling plant was fined $195,000 for non-compliance with lockout/tagout. There were no reported injuries associated with this fine, just an OSHA audit stemming from an employee compliant.
The intent of OSHA's regulation 1910.147 — Lockout/Tagout is to protect employees and property from damage due to unexpected start-up and reenergiziation of machines during servicing. In other words, the intent is to keep someone from starting the equipment when an employee is inside it.
So why wouldn't employees want to utilize this program every time they service a machine? To better understand the real problem, ask yourself as a safety professional: “Do you lock out the energy on equipment when you service it at home?”
When you change a light bulb, do you apply a device on the switch or the breaker for that source? When you work on your car, do you chock the wheels, remove the key and disconnect the battery to prevent start up and movement?
Chances are most of us do not take these precautions at home. Reasons vary, from a feeling that there is safety in home-based situations that does not exist at work because we trust that nobody will start equipment while we're working on it, to knowing that no one is around to interfere. At home, we feel safe by yelling out, “Don't turn on that light switch, I'm changing the bulb.” And while it's debatable if we actually are safe at home performing maintenance tasks in this way, it's pretty clear that we're not safe when that technique is applied in the workplace.
LOTO COMPONENT 1:3 — ANNUAL TRAINING & AUDITS
Every time I conduct lockout/tagout training, I start by asking trainees a few basic questions. I sometimes am surprised when I hear their answers to this question: “Why do you think lockout/tagout accidents continue to occur in the workplace?”
I expect most to say “complacency,” “laziness” and maybe, “forgetfulness.” I'm surprised when I hear, “I need lockout/tagout like I need another hole in the head,” or, “OSHA doesn't understand that our process can't be shut down each time we climb in there. It would cost too much.”
Those two responses tell me that not only do some employees not understand the OHSA regulation (a mindset that can be overcome with training), but they don't believe that their lives are more valuable than the process or product that the company is producing.
If the culture in a workplace supports anti-OSHA regulations and anti-safety thinking, it's only a matter of time before there is a major accident. A safety manager's top priority should be to ensure the company culture supports safety as a value in the workplace and not a hindrance. Without employee involvement at this level, nothing else will matter.
Training should include an overview of the major components and definitions outlined in 1910.147, a review of your new lockout/tagout procedure and instruction on how to use that lockout/tagout procedure to safely bring equipment to a zero energy state. The training should be grouped with the annual inspection of the lockout/tagout program. Here is what OSHA requires for the annual lockout/tagout program “check-up:”
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All lockout/tagout procedures must be audited at least annually to ensure they are accurate and compliant.
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All authorized employees must be trained with a specialized training program geared for authorized employees. Affected employees must be trained on lockout/tagout awareness.
Employee inspections must be performed to ensure the lockout/tagout procedure is being properly utilized. While the minimum requirements are for a sampling group once a year, we recommend performing monthly, quarterly or random checks throughout the year to ensure authorized employees properly are utilizing the system. That way, any deviations can be corrected to maximize the effectiveness of your new program.
LOTO COMPONENT 2:3 — MACHINE-SPECIFIC PROCEDURES
Step 1: Allocating the proper resources.
Once training is given and the employer feels confident that managers and all line employees are involved in improving workplace safety, lockout/tagout procedures can be developed. Many companies make the mistake of not giving this aspect of the program enough attention and end up glossing over it with inadequate detail or, worse, inaccurate detail. From our experience, 80 to 90 percent of the legacy lockout/tagout programs we are hired to replace are not only non-compliant and incomplete, but also inaccurate and potentially more dangerous than not having any information at all. This can happen for many reasons.
For example, an employer starts out on the right track and hires someone full time to create a lockout/tagout program. That person finishes his or her job and gets promoted, quits or gets laid off because the program now is in place. Without any accountability, the best lockout/tagout program in the world likely will erode in 1 year when the procedures aren't updated to reflect equipment changes.
Depending on the industry, it's likely that 10 to 30 percent of the equipment will change every year. This means that if the procedures aren't updated at least annually to reflect this equipment change, they become a liability to anyone who uses them.
In the next scenario, an employer hires interns to create the procedures. The company may have saved a bundle hiring an intern to create the procedures, but what's the likelihood that the intern will finish the program before his or her term is up? Common problems we've seen with this approach are that the program is incomplete, inaccurate or inconsistent.
Finally, many employers use their in-house resources to complete the procedures. This sounds like a great idea at first and it actually can work if it's set up properly. Unfortunately, too many employers underestimate the amount of resources necessary to complete the program. With the 10 percent to 30 percent equipment changes every year, it's likely that some programs never will be completed because the program development process wasn't set up or funded to continue beyond the initial setup phase. In extreme cases, we've seen one worker assigned to create hundreds of procedures. In over 2 years, the program was 20 percent complete and more than 50 percent of the information it contained was inaccurate because of equipment changes that took place in the 2 years. Talk about a hopeless situation!
Sometimes, you do get what you pay for. This could be one of those times where the best option is to hire a consulting firm to develop the lockout/tagout program in the timeframe you need and at the price you want to spend. With a consulting firm that specializes in lockout/tagout compliance, you can have your program up and running in a matter of months, verses years. Any good consulting firm will provide a scalable approach to employee involvement, depending on the client's preferences. This means that after the program is in place, employees should feel like they were part of the process of developing the procedures and will be more likely to utilize them.
Step 2: Choosing a format that works for you.
The lockout-tagout format you choose is especially important and will change based on the circumstances and industry. For instance, a bottling plant may benefit from a significantly different format than a power generation facility because of the number of steps involved, type of equipment, and internal rules and policies.
There are three major formats that are most popular for various reasons. Below is a list of the formats and the advantages/disadvantages of each:
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Text-Based Format: Pros: Inexpensive and quick to set up. A lot of information can be presented in a small space (one page is typical). Cons: Difficult to understand, interpret and utilize on a day-to-day basis.
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Line Drawing-Based Format: Pros: Provides a top view of the equipment and shows in a map style where the isolation points are. Information can be accessed more quickly than text based procedures. Cons: May be difficult for some to interpret and understand. Procedure creation time is considerably greater than text based procedures.
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Picture- (or Graphical) Based Format: Using digital pictures to show users where the isolation points are located on the equipment. Pros: Proven to be the most efficient way to convey mass amounts of information quickly. Operators of all levels of expertise find this format useful and easy to understand. Cons: Cost of implementation may be slightly higher, however cost of maintenance is easier (it's easier to insert new picture rather than modify a line drawing).
Step 3: Deciding on a software foundation for your procedures.
Underestimating the importance of choosing the best software for your company may lead to serious calamities down the road. If you have one to 10 procedures, Wizard-based software might be the best bet. If you have 10 to 100 procedures, you may find that Wizard-based software is okay, but prefer the flexibility of a customized template. If you have 100 to 1000 procedures, sticking with a tested, proven foundation like Microsoft Office might be the best bet.
There are a few software solutions that exist in the market that specialize in procedure creation. However, they all were built for a specific size job and industry in mind, so evaluation of this software before implementation is critical. Some of the software has been around for nearly 30 years, and may not have the modern look and feel you would expect.
One of the best options for many companies may be to build a customized template in the Microsoft Office environment (Word, Excel or even PowerPoint) and take advantage of its proven reliability, compatibility and flexibility. This will help “future proof” your lockout/tagout system by basing it on the idea that Microsoft may be the most compatible work platform that exists. One disadvantage of using Microsoft Office is that there is less guidance when creating procedures in-house, so the learning curve might be greater than a Wizard-based software.
LOTO COMPONENT 3:3 — CORPORATE POLICY
One of the biggest mistakes an employer can make after spending considerable time and money creating training and procedures is to neglect the corporate policy on lockout/tagout. Part of the training should be to suggest employees refer to the corporate policy if they are unsure about when to lock a piece of equipment out or how to lock out a piece of equipment.
Without a corporate policy, it is left up to the employees to decide how to handle the “gray areas” that aren't spelled out in the OSHA regulation. A good corporate policy at least should address the following areas, plus reinforce the basic structure of the 1910.147 regulation:
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What protocol outside contractors should follow.
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The process to revise a procedure if a discrepancy is identified.
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The corrective action that may taken if the lockout/tagout procedures are not properly utilized.
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Assignment of responsibility for new procedures when new equipment comes in.
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A basic procedure creation flow chart that the employer wants followed when a new procedure is required.
Any special circumstances, equipment or process that the employer has identified as exempt from lockout/tagout and the reason. This especially is important for processes that the company doesn't want locked out by their employees under any circumstances (emergency medical air, fire protection equipment, battery back-up units, safety systems, servers, etc.) While those systems still may need to be locked out under special circumstances, it may be best to acknowledge the list of unique equipment in a policy to avoid any expensive or dangerous misunderstandings by the authorized employees.
PREREQUISITE — COMPANY CULTURE
At the end of the day, no safety program will protect an employee from injuries or death if they are intent on taking risks anyway. That is why the most important prerequisite for any safety program is the company culture. With the right company culture, the safety program will be perceived as a guide, not a hindrance.
When employers decide they are ready for modern lockout/tagout programs that can withstand the test of time, they not only need to understand the three major components involved, but also the investment required to implement and maintain a program.
The good news is that when a high quality lockout/tagout program is in place, the benefits are immediate and lasting. Benefits include increased employee morale, decreased downtime (lockouts take less time to implement and restore), decreased workplace accidents and decreased insurance rates. In today's economy, when many employers are watching their bottom lines closely, they just might benefit from implementing or upgrading their lockout/tagout programs.
Jimi Michalscheck is the vice president and co-owner of ESC Services Inc. (http://www.escservices.com), an engineering firm that specializes in the creation of lockout/tagout procedures.