Lockout/Tagout: Are the Hazards Misunderstood?

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:”

• All lockout/tagout procedures must be audited at least annually to ensure they are accurate and compliant.

• 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.