Companies should assess their lockout tagout (LOTO) programs for gaps that may significantly impact safety. We often find three significant gaps.
One gap is related to accurately assessing the needs of and training for affected employees. Many employers train their “authorized” workers, but do not identify and appropriately train their “affected” and “other” employees beyond general awareness. Depending on the work setting, employees might be unknowingly performing activities that would require locking energy sources.
We were involved in an unfortunate and preventable incident that resulted in a serious injury. The injury occurred during a change-over procedure that the company identified as a ‘normal’ part of the work process and therefore not requiring LOTO. An employee suffered burns when a steam valve was inadvertently left open, and steam was released. The injury would have been prevented if LOTO was required on all energy sources. We’ve read of many other preventable injuries and deaths from electrocutions and being caught in equipment while making adjustments when equipment was operating. A recent such incident was a fatality when an employee tried to free a pan that had become stuck. He got caught in the machinery when he crawled under a conveyor belt to free the pan.
Another gap is when companies provide basic classroom training, but there is no follow-up to ensure that procedures are being correctly implemented or that they can in fact be correctly implemented as taught. Classroom training is often not enough. Follow-up, further discussions, and demonstrations of procedures are critical steps to learning and training implementation.
The third, but not least gap, is failure to develop equipment specific LOTO procedures. Often companies incorrectly interpret the requirement to be a detailed general policy and procedures alone. However, this is not enough to ensure safety and compliance with the standard. A written procedure needs to be developed for each piece of equipment that clearly outlines energy sources, lockout procedures, and the locks required. This is often accomplished with pictograms to clearly identify where to apply locks.
The OSHA Standard CFR 1910.147, outlines measures for controlling hazardous energies—electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources. Some of the other most critical requirements from these standards are outlined below:
- Develop, implement, and enforce an energy control program.
- Use lockout devices for equipment that can be locked out. Tagout devices may be used in lieu of lockout devices only if the tagout program provides employee protection equivalent to that provided through a lockout program.
- Ensure that new or overhauled equipment is capable of being locked out.
- Develop, implement, and enforce an effective tagout program if machines or equipment are not capable of being locked out.
- Develop, document, implement, and enforce energy control procedures.
- Use only lockout/tagout devices authorized for the particular equipment or machinery and ensure that they are durable, standardized, and substantial.
- Ensure that lockout/tagout devices identify the individual users.
- Establish a policy that permits only the employee who applied a lockout/tagout device to remove it.
- Inspect energy control procedures at least annually.
- Provide effective training as mandated for all employees covered by the standard.
- Comply with the additional energy control provisions in OSHA standards when machines or equipment must be tested or repositioned, when outside contractors work at the site, in group lockout situations, and during shift or personnel changes.
According to OSHA, following proper Lockout / Tagout procedures prevents an estimated 120 fatalities and 50,000 injuries each year. Hopefully no one reading this has had an issue with your LOTO program; however, do you know of any precursors that are occurring as well as any gaps in you program? Identifying both may help to prevent a future incident.