Are you one of the lockout tagout greats?
What happens beyond a lockout tagout (LOTO) program implementation is what separates the rare few greats from the rest of the overworked industry.
- Are your lockout tagout procedures updated to reflect changes and upgrades in your facility?
- Do your production lines have specific isolation valves and electrical disconnects in place?
- Are you conducting annual LOTO procedures audits? You would be surprised to know the answer to this question is often no.
- Are you enlisting qualified professionals to conduct a gap assessment on your procedures? This is a critical step to the effectiveness of a LOTO program. Why? Because the annual audit process becomes is often seen as yet another task for burdened safety professionals leading to oversights.
Scaling can break even the best LOTO programs
Enterprise growth can also become the root of many challenges, mainly if safety programs are not correctly scaled. Growth outpacing safety programs is one of the main reasons the 1910.147 control of hazardous energy (lockout/tagout) is on the top 10 list of OSHA’s most cited standards year after year.
In 2020, OSHA assessed a proposed $7.5 million in penalties for violating the LOTO standard, making it the sixth most frequently cited agency standard. Food manufacturing, fabricated metal products, plastics and rubber products, wood products, and primary metal manufacturing are the most heavily penalized industries.
Common LOTO Procedures Oversights
Conducting LOTO gap assessments helps you ensure the procedures in place can protect employees from injury and equipment from damage. Thorough annual audits identify procedure adherence gaps. The problem is that in-house personnel can miss critical items when performing these gap assessments due to the mounting demands on safety professionals. Some of the most commonly found oversights include:
- Incomplete documentation of required lockout tagout training
- Failure to update procedures to reflect changes in operations and equipment
- Failure to release equipment stored energy
Effective Energy Controls Procedures
OSHA estimates that LOTO standards compliance prevents 120 fatalities and 50,000 injuries yearly.
These numbers clearly illustrate the tangible effect proper LOTO procedures can have on employee safety, regulatory fines violations avoidance, and uptime.
Proper energy control procedures involve the following:
- Identification of the energy types employed within a piece of equipment
- Identification of energy isolation for sources external to the equipment
- Identification of stored energy after shutdown and proper steps to release it
- Identification of energy controls and verification of their safety compliance and effectiveness
- Evaluation of current procedures and adherence
- Ensuring clear communication of LOTO procedures for each piece of equipment
The Dos and Don’ts of Lockout Tagout Procedures
DO: Share ownership of your lockout tagout program
Providing easy access to the standards is a starting point, not the endgame. Your people need to be active stakeholders in the success of your lockout tagout program, including a commitment to training, reinforcement of protocols, and willingness to communicate gaps and opportunities openly.
DO: Approach your equipment with fresh eyes
Always look at your equipment through a safety lens. How long an asset has been in your facility does not determine how you approach its LOTO procedures. It helps to look at all assets as if they were new additions to your line.
DO: Ask questions
Be curious. Ask questions about your assets, including energy sources, how they operate, what they do, maintenance procedures, power shut-offs, training manuals, and OEM materials.
DO: Craft easy-to-understand LOTO procedures
Keep in mind your people’s level of experience and seniority when crafting LOTO procedures. Your documented procedures need to be clear, easily accessible and answer critical questions like how to recognize when an equipment piece is at a zero-energy state.
DO: Label control points
A clear labeling system that correlates to documented procedures should easily identifiable by your employees. Labeling control points is crucial to eliminating potential errors. Approach this step from the perspective of a brand-new tech working on a piece of equipment.
Don’t stop with simple digital training content
While computer-based training programs, videos, and other digital assets are powerful tools, best-in-class safety programs rely on rich content, assessments, and field applications. Reinforcement is key to success.
Don’t forget about automation
As the equipment in every industry continues to move toward automation, assessments of new risks and safety procedures must be performed and documented. Furthermore, as equipment evolves, so do the requirements to energize these assets, which means LOTO procedures must be revised.
DO: Rely on QR code technology
Labeling software has improved a facility’s documentation and audits of hazardous energy controls. QR codes ensure that labels placed at each energy isolation point (EIP) are unique; this helps eliminate mistakes during maintenance and servicing. Scanning QR codes with mobile devices and tablets provide employees easy access to view, complete, and audit LOTO procedures.
DO: Use technology to standardize visibility across multiple sites
Safety procedures at the asset level are essential to keep employees safe and protect equipment. Asset management and visualization software can provide a comprehensive view of a facility or multiple facilities. You can tie asset data to your existing computerized maintenance management systems (CMMS).
The world of LOTO is changing. Traditional control measures such as physical locks and tags are being challenged by computer-based controls as the workplace environment becomes more automated and digital. Most industrial environments rely on multiple energy types ranging from electrical, thermal, and gas to radiation, vacuum, explosive, and propellants; each source calls for a tailored safety approach. Knowing that a revised OSHA standard is in the works, our advice is: to be proactive with our digital lockout/tagout program.
Use internal experts from different departments or a “fresh pair of eyes” from a third-party service to assess if gaps exist between your written procedures and program and your sources of energy, control procedures, labeling, data collection, and training. Remember that there are tools and software available to help you update and build a best-in-class LOTO program to protect your people and equipment.
Read our full Taking a Deep Dive into the World of Lockout Tagout article in OH&S Magazine.
SEAM Group: Your Comprehensive Lockout/Tagout Partner
LOTO Program Development and Implementation
Each LOTO program is custom developed for compliance with the applicable OSHA regulations and standards as well as your company’s specific requirements and policies.
Annual Audits and Reviews
Verify that Energy Control Procedures (ECP) are accurate and that employees are able to demonstrate proper energy isolation of equipment to perform servicing and maintenance.
Compliance GAP Assessment
An in-depth report of where your LOTO program to identify and make recommendations on overlooked areas, training gaps, and improvement opportunities