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For more information on Lockout/Tagout (LOTO labeling), visit our On-Demand LockOut TagOut page.
Lockout/Tagout is a major OSHA-inspection focus. In fact, it remains the #1 most cited violation for general industry even after twenty years in force. But, rather than focus on the negative aspect of non-compliance and citations, focus instead on this: comprehensive and thoroughly-followed LOTO programs:
• SAVE LIVES – preventing an estimated 250,000 incidents, 50,000 injuries and 120 fatalities annually!
• CUT COSTS – significantly; both lost employee time and insurance costs
• IMPROVE PRODUCTIVITY – minimizing equipment downtime
• are BEST PRACTICE – being widely adopted across industries and industrialized countries
Best Practice 5-Step Plan
Do you want to be in compliance with both the letter of the OSHA law and the spirit of it so as to provide a safe work environment for your employees? Certainly! One way to accomplish both is to use this 5-Step Plan to enact an effective energy control program. Doing so will bring your organization into compliance and put you on the road to the greater benefits noted above.
Briefly, the 5-steps are as follows:
• STEP 1: Develop and document your energy control policy/program
• STEP 2: Create and post written, equipment-specific lockout procedures
• STEP 3: Identify and mark all energy control points
• STEP 4: Train your employees, communicate and conduct periodic inspections
• STEP 5: Equip your employees with the proper lockout tools and warning devices
Step 1: Develop Energy Control Policy/Program
Successful Program Development:
OSHA has a Lockout/Tagout Tutorial on its www.osha.gov website that provides additional advice on developing an energy control policy/program.
This written lockout document is your starting point; it establishes the ‘nuts and bolts’ of your overall lockout program. After you’ve completed this summary, you can continue with what is possibly the most important step for your workers … writing machine-specific procedures.
Step 2: Written, Equipment-Specific Lockout Procedures
Related Incident & OSHA Citation:
OSHA proposed $112,500 in penalties to a large employer for repeat violations, including failure to develop proper energy control procedures. Less than three months earlier, the same organization was cited for $2.78 million in proposed fines for 42 willful violations of the lockout/tagout standard, including failure to utilize lockout procedures before attempting to clear equipment jams, and failure to provide training to 4 employees responsible for clearing jams. Tragically, an employee had been killed in a related accident.
Successful Program & Procedure Development:
Lockout procedures must be documented and must identify the equipment covered. The procedures should detail specific steps for shutting down, isolating, blocking and securing equipment to control hazardous energy. Steps for the placement, removal and transfer of lockout tagout devices should also be included.
Graphical lockout procedures, which include photos, are best practice in the industry today, as they provide clear, visually- intuitive instructions for employees to follow.
A typical medium sized facility will have several hundred pieces of equipment – each of which requires a specific lockout procedure. The equipment list will usually include boilers, chillers, generators, conveyors, automated and production equipment, pumps, compressors and more.
Many companies trust their written procedure development to outside technical experts, who can evaluate the facility’s operating and production equipment and develop complete and correct lockout procedures for the entire range.
Step 3: Identify Energy Control Points
Related Incident & OSHA Citation:
OSHA cited a manufacturer for failing to protect workers from electrical hazards that contributed to the death of a worker. The employee was working on electrical equipment that had not been properly labeled and disconnected. OSHA issued a willful citation for failing to properly label electrical equipment, and a serious citation for failing to have adequate procedures in place to render machinery inoperable while maintenance and repair work were performed.
￼Successful Training, Communication & Inspections:
Locate and mark all energy control points, including valves, switches, breakers and plugs, with permanently placed labels or tags. Cross reference each label and tag with the corresponding step # in the posted energy control procedure for that equipment. Include information about the magnitude and purpose of the control point as stipulated by OSHA for electrical disconnects and recommended by ANSI for all isolating devices.
Step 4: Training, Communication & Inspections
Related Incident & OSHA Citation:
OSHA conducted an investigation following the death of a fleet mechanic who was pinned between two trucks while performing maintenance on one of the vehicles at the company’s worksite. “This was a preventable tragedy” stated the director of OSHA’s area office. OSHA issued one willful violation for alleged failure to implement and train employees on a lockout/tagout program to be used when performing vehicle maintenance.
Successful Training, Communication & Inspections:
First, establish formal training programs for each of the three categories of employees for lockout; ‘Authorized,’ ‘Affected’ and ‘Other’ employees. OSHA provides advice on how to train, and verify that the training is up-to-date.
Step 5: Provide Proper Protective Products
Related OSHA Citation:
OSHA opened an investigation after receiving notification that an employee was crushed while servicing a hydraulic press that had been disabled but not protected against accidental energizing by locking out potentially hazardous energy sources. OSHA issued four willful- and fifteen serious citations, alleging, in part, that the company failed to control potentially hazardous energy during machine repair or maintenance, and was deficient in having personal identification of lockout devices.
Equip Your Employees with the Proper Lockout Tools & Warning Devices:
Ultimately, it’s the proper and religious application of the lockout hardware per the established procedures that makes for a successful lockout program. To this end, it’s very important to know and document specifically what devices are acceptable for use at each and every lockout point. There is a tremendous range of sizes and shapes of valve operating handles, circuit breaker switches and various other energy control means. A leading lockout device provider will have developed product series that properly fit the majority of these.