Lockout/Tagout Compliance: Getting the Most from Your Lockout/Tagout Program

As the gavel slams down, the CEO of the medium-sized pharmaceutical company looks down in disbelief. They lost the case before the Supreme Court and now they have the tough task of rebuilding morale and their (obviously inadequate) lockout/tagout (LOTO) program. The judges determined that the company's non-compliant LOTO program was to blame when a large autoclave that was being serviced inadvertently was re-activated remotely by a control room operator, killing three workers.

The company has a new attitude towards safety now and a new safety budget. The board of directors determined that they were going to completely revamp their LOTO program in house, starting from the ground up. After such a horrific tragedy, everyone in the company — from management to line employees — is looking for answers. Not only about what happened, but more importantly, how can they ensure it never happens again.

When an accident of this magnitude occurs, the knee-jerk reaction by upper management is to button up their policy and restrictions so tight that they don't allow for the most important element in safety — the human element. Because there's no way to write a policy that covers every possible scenario that authorized employees will encounter, it's more effective to help teach and enforce an approved approach towards the likely scenarios that will be encountered in their facilities.

CIRCUMVENTING EXCUSES

The result of making a policy and program too restrictive: more accidents. When we give trainings around the country in different industries, we hear the same valid concerns brought up when we help implement the new LOTO program or come in to help after a program has been made too restrictive:

• How can I be expected to lock it out when it needs to be partially energized to do my service work?

• When I lubricate the chain right now, it takes me 5 minutes. If I have to lock it out each time I lubricate each part of the chain it now will now take me longer than an hour.

• Our equipment jams up three to five times an hour and I have to clear these jams to keep product moving. It takes me less than 30 seconds to clear the jams right now, but if I have to lock it out each time, it will take hours and production will suffer greatly.

The list goes on, but the common theme is that authorized employees don't realize that the program implemented to save their lives is practical. And management does not do a good job of explaining the value of the LOTO program, simply saying, “Do it.” Then the employer realizes that they're paying a cost for the program and production is down or accidents are up or both.

So what is the answer? As a manager, how do you ensure your employees are safe without damaging the business? As an authorized employee, how do you get your job done safely without taking so long to do simple tasks?

The answer is simple: Allow employees to make decisions, but make sure the decisions are guided by a firm understanding of what is and isn't allowed.

It won't be the same, specific answer for every company or industry. OSHA provides guidelines in the regulation that must be followed and employers are expected to find a good fit for their business while staying within these parameters.

SOLUTIONS

Here are some solutions that might surface from an authorized employee working under a high-performance, employee-driven LOTO program:

Partial energization: Steve, an authorized employee, realizes that to program the robot properly, he needs to be inside the guarding and very close to the robot and part. He remembers from the company policy and training that he can perform this task if he ensures he has the equivalent level of safety that a full lockout would provide. Since this service only is related to training the robot, he ensures he has the only control pendent and thus full control of starting/stopping the robot. He now can safely and legally be inside the guarding and close to the equipment while conducting this task.