Lockout/Tagout Procedures Help Save Lives

Here are four steps to get you in compliance.
Tom Campbell

You’ve got the safety padlocks and lockout tags, the circuit breaker, electrical and valve lockout devices, and you’ve even wall-mounted the departmental lockout stations in your facility. So you should be covered for the OSHA Lockout/Tagout inspection, right? And you should be good to go with your employees, yes? Not necessarily. Did you know that none of the top five most frequently OSHA-cited sections of the Lockout/tagout standard is specifically about the protective materials and hardware (i.e. the lockout padlocks and tagging devices)? Not one!

The top five sections cited by OSHA are:
(1) Failure to develop, document and utilize PROCEDURES
(2) Failure to establish and implement a WRITTEN PROGRAM
(3) Failure to conduct a PERIODIC INSPECTION of the energy control procedure
(4) Failure to provide TRAINING as described by OSHA
(5) Failure to clearly OUTLINE THE SCOPE AND RULES to be utilized, and the means to ENFORCE COMPLIANCE

That’s not to say that the products designed and used for lockout aren’t important, because they certainly are. It does, however, speak to the fact that lockout compliance is first and foremost about having a sound program and machine-specific procedures in place, along with comprehensive training and effective communications for your employees.

Lockout/Tagout is a major OSHA-inspection focus. In fact, it’s the #1 most cited violation for general industry. But, rather than focus on the negative aspect of non-compliance and citations, focus instead on the benefits of having a comprehensive and thoroughly followed lockout/tagout program:
• 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
• IMPROVING BEST PRACTICES – being widely adopted across industries and industrialized countries

FOUR-STEP PLAN TO AN EFFECTIVE LOCKOUT/TAGOUT PROGRAM
Do you want to be in compliance with both the letter of the OSHA regulations and the spirit of it in order to provide a safe work environment for your employees? Certainly! One way to accomplish both is to use the following 4-Step Plan to help create your energy control program. Doing so will help bring your organization into compliance and help your organization achieve the benefits noted above.

• STEP 1: Develop and document your energy control program with written procedures
• STEP 2: Identify and mark all energy control points
• STEP 3: Train your employees, communicate and conduct periodic inspections
• STEP 4: Equip your employees with the proper lockout tools and warning devices

STEP 1: DEVELOP ENERGY CONTROL PROGRAM & PROCEDURES
Related Incident & OSHA Citation: October, 2007. OSHA initially 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: The written lockout policy is your starting point. It establishes the “nuts and bolts” of your overall lockout program. Begin by reviewing and then documenting your program. Continue with machine-specific procedures development, training and periodic inspections. OSHA has a Lockout/Tagout Tutorial on its www.osha.gov website that
provides additional advice.

Lockout Pro™ Graphical Lockout Procedure Software includes a thorough sample energy control policy that can serve as a guide as you develop your own comprehensive energy control program. However, the overriding benefit of Lockout Pro is that it allows you to create and manage clear and easy-to-follow visual machine-specific procedures for all your equipment.

STEP 2: IDENTIFY ENERGY CONTROL POINTS
Related Incident & OSHA Citation: November, 2002. 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 Energy Control Point Identification:

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.
Grainger offers a complete line of labels and tags for identifying and disconnecting various energy control points. For greatest convenience, portable and industrial label makers will produce custom labels, and also link to the Lockout Pro™ procedure output.

STEP 3: TRAINING, COMMUNICATION & INSPECTIONS
Related Incident & OSHA Citation: August, 2007. 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 companys 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: 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. Grainger offers training and communication products including DVDs, handbooks and signs. Lockout Pro software includes a training module and employee quiz that can be administered upon completion of your employee training. It also provides a straightforward explanation of the periodic inspection requirements.

STEP 4: PROVIDE PROPER LAYOUT TOOLS & WARNING DEVICES
Related OSHA Citation: March, 2007. OSHA investigated 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 consistent application of the lockout hardware per the documented 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.

As this article reminds us, it’s not just about the products, and it’s not just about avoiding a fine: Establishing and maintaining a comprehensive Lockout/Tagout program that is understood and embraced by your employees may help cut costs, improve productivity and, above all, potentially avert an incident or employee injury.

Webinar Series:

To view a presentation from a recent webinar on this topic, go to:

www.grainger.com/webinars/lockout_tagout_presentation

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