This article was written by Eric Prinzing for Occupational Safety & Health. It is reprinted here with permission.
Lockout/Tagout compliance is a crucial safety requirement. Preventing the accidental start-up of energy during repair and maintenances ensures the safety of workers and helps create a productive workplace.
The OSHA Lockout/Tagout Standard (1910.147) provides clear lockout safety requirements. Despite this, lockout/tagout (LOTO) continues to be found in OSHA’s top 10 most frequent cited standards. It should be seen, then, as a serious and widespread concern. Here are 6 tips to help you stay compliant:
1. Choose the right devices – A lockout device is an extremely important component of a LO/TO program. Machines, circuit breakers, plugs, switches, push buttons, and valves are just some of the items that often require lockout devices. Since there are so many choices, choosing which device or set of devices is overwhelming. There are two considerations that will help: necessity (knowing exactly what you need) and organization (using standardized devices and tools to help keep your devices organized).
First, determine exactly what you need. OSHA’s guidelines are certainly helpful, but each workplace is unique. Create a list of all machines or electrical components that may need lockout devices. This will make buying the most appropriate devices or kits easier because most are designed to meet a specific application.
Second, standardize and organize your lockout devices. Lockout Stations are one effective way to store and organize necessary devices. This has several benefits: Not only do stations store necessary devices, but also, they save valuable space and promote efficient operations. If devices are organized in a station, workers know exactly where to find them, when preparing for a maintenance or repair. Padlocks should be standardized by size and color so workers can easily identify function and ownership.
2. Thoroughly Document Procedures – Lockout procedures need to be formally documented. This keeps workers and management on the same page and helps to eliminate any potential confusion. Documentation also provides workers with a valuable training resource. Formal documentation is required by OSHA, but given the differences in workplaces and machines, not every procedure will be the same. It is especially important, then, to make sure the procedures are as effective as possible.
Procedures should thoroughly detail the steps needed to shut down and isolate hazardous energy. The procedures must describe how to safely place and remove all relevant lockout/tagout devices.
In order to make the lockout process as easy to follow as possible, procedures should be posted near the relevant machine/equipment. Machine-specific photographs detailing each step are highly recommended. Photographs have a distinct advantage over written instructions or even graphics because the provide a specific and intuitive visual reference point for workers.
3. Clearly Mark All Isolated Points – All energy control points should be clearly and permanently marked with standardized tags or labels.
Tags and labels should be easily visible. It is also very important to make sure all energy isolation points are consistent with the machine-specific procedures discussed in tip #2.
4. Develop a Rigorous Training Program – Effective training is an indispensable part of a successful lockout program. It can also be one of the most difficult parts because all workplaces and workforces need to be trained according to their specific needs.
It is important for each worker to know exactly what his role is. Tasks should be clearly defined and clearly assigned to the appropriate worker. There are three types of workers involved in lockout operation: authorized, affected, and other. An authorized employee is directly involved in locking out equipment and machinery scheduled for repair or maintenance. An affected employee is someone whose work is affected by lockout procedures. Usually, this means an employee who works with the equipment being locked out for service or repair. An employee is classified as other if he/she does not work with the machine/equipment, but works in the area where the equipment is located. Each worker needs to know what type of employee he/she is, and strong communication needs to be developed among all workers. Authorized employees must clearly alert all affected employees when a lockout device is placed or removed. In order to prevent unsafe removal of devices, only authorized employees can remove devices they have placed. Lockout padlocks have room for workers to clearly write their names in permanent ink, which underscores the strong need for clear assignments and individual responsibility.
As with procedures and isolation points, documentation is an important component of training. Recording exactly what types of training have occurred is helpful on several levels. It helps management make sure all workers have been trained, and they are trained for doing the right tasks. Any gap in training can be easily found and corrected. It documents when training took place, which helps workplaces, plan ahead. If you know when your last training session took place, it is easier to plan when the next one should be implemented. Finally, looking at documentation of lockout training can help see your program from a new, more objective perspective. Suggestions can then be taken into account and improvements can be made.
Training also should be tailored to each specific workplace. If one has a multilingual workforce, for instance, multilingual tools, signs, and documents should be used. Workers should be encouraged to relate their specific safety needs.
OSHA requires that lockout/tagout training occur annually. Yearly training should be seen as a bare minimum rather than ideal. In many cases, it would be helpful to revisit training exercises more frequently than yearly in order to ensure that critical repairs and maintenance are being done safely. Also, repeat training helps workforces keep a “safety first” mentality. When deciding exactly how much training is necessary, it is important to keep workers engaged in the process and to make sure their ideas and concerns are carefully considered.
5. Evaluate –Careful evaluation is an invaluable tool for improvement. The success of lockout training and written procedures can only be truly gauged after they have been put to use in an actual maintenance or repair situation. Evaluation is necessary to make sure the training exercises, procedures, and devices are working properly. It also affords opportunities to make improvements that may not have been obvious in the training stage.
OSHA provides rules for periodic inspections. These should be followed closely and provide an excellent foundation for evaluation and improvement. Inspections need to occur at least annually and be performed by an authorized employee who is not involved in the procedure being inspected. All deviations must be corrected and all roles must be thoroughly reviewed. The inspection must also be documented. The date of inspection, procedures, machines/equipment involved, and names of workers performing the inspection must be recorded.
6. Evolve – A good lockout program should always be able to evolve. OSHA may introduce more requirements or stringent guidelines. It is important to make sure your program is up to date. Open communication between all levels of employment also will help your lockout program reach its potential. A program that encourages communication can identify strengths and weaknesses more efficiently than a program that remains static and unchanging after initial training. Employees should be encouraged to communicate which training exercises are working well and which ones need “tweaking”. A lockout program can then go beyond fulfilling minimum requirements: It can be tailored to your workplace and your workforce.
The ultimate goal is maximum safety for your workers, and all steps should be taken to reach that goal.