In part 2 of a two-part series about lockout/tagout compliance, the author examines the importance of lockout/tagout and the components of an effective program.
Changing Attitudes
When we train around the country, we often hear the same stories and witness the same attitude transformation from the beginning of the training to the end. At the beginning the attitude might be something like: “Lockout/tagout makes my job more difficult” or “Lockout/tagout is huge over-kill for simple maintenance tasks.” Or, my personal favorite: “I've got so much experience that I don't need to follow machine-specific procedures that show me how to lock out the equipment.”
By the end of the training, those attitudes change to: “Wow, I didn't realize that I was putting my life in danger so often” or “I can't believe I've been taking so many shortcuts. I didn't know any better.” According to the U.S. Department of Labor, the number of non-fatal amputations hovers around 8,000 and has every year for the last 5 years.
So what does it take to have not just an OSHA-compliant LOTO program, but a LOTO program that works well for your company? It's quite simple really, but it takes a buy-in from upper management and cooperation from the LOTO program's authorized employees to ensure it's properly implemented and maintained. The five components to an effective LOTO program are:
A corporate policy
Your policy should be written in a way that is clear and easy for your authorized employees to understand (not a bunch of lawyer talk). Like your LOTO procedures, the policy should remain dynamic and change with conditions. It should be provided to the authorized employees and expected that they read and understand it, and it should address all aspects of the program to ensure they know how to lock out the equipment and when to lock out the equipment.
Machine specific procedures
This is perhaps the most difficult part of the regulation in terms of compliance and also the most notoriously cited part of CFR 1910.147. So many companies believe that simple equipment like exhaust fans, bench grinders and drill presses don't need machine-specific procedures. Actually, each machine must meet eight criteria set by OSHA in CFR 1910.147(c)(4)(i) to be exempt from having a pre-written machine-specific procedure available for the authorized employee. Failure to comply with this part of the regulation could lead to individual OSHA fines of up to $70,000 per piece of equipment that doesn't have a procedure.
Training
Training is required for all authorized and affected employees and it's expected that this training is kept up to date when changes in your program occur. We recommend that training is given annually to all authorized employees. Use a quiz to ensure and document comprehension.
Annual auditing
Both authorized employees and each LOTO procedure must be audited every year to ensure the equipment hasn't changed and ensure the procedure still is readily available and accurate. Authorized employees must be tested at least annually to ensure they fully understand how to and when to properly apply LOTO.
LOTO equipment/devices
To ensure you have all the necessary tools to properly lock out your equipment, it's going to likely take more than just locks. There are commonly overlooked LOTO devices. Hasps and lock boxes are to be utilized when there is more than one person working on the equipment. Remember, anyone working on the equipment has to be authorized and all authorized employees need to be under lock protection when servicing the equipment. There are dozens of specialized valve devices on the market and many are designed to work best for specific valves. It's important to evaluate the devices and purchase the ones that are easiest to use and work best with your type of valves. When you turn off a breaker many times the only way to lock it out is to apply a specialized breaker device that is designed to fit your style of breaker. Pulling the fuse is not enough for LOTO. OSHA requires that when possible, you install a device to prevent accidental re-energization of the equipment or energy. We recommend that you use plastic-bodied locks and re-usable tags to help ensure your program is clearly defined and easy and inexpensive to maintain.
Editors note:
Consult our legislation section for relevant South African OSHA requirements. The aspects addressed will go a long way to ensuring you have an effective LOTO programme in place.
Copyright 2017 by Penton. Used with permission from EHS Today: http://ehstoday.com/basics-of-lockout
