Inspectors Discuss Problems They See with the Lockout-Tagout Rule
"There's nothing ambiguous about it."
"There are some very good standards. Lockout-tagout is one."
"It's a killer if it's not followed. Of the fatality investigations we do, quite a few are the direct result of improper lockout-tagout."
"It's not a big investment: You gotta buy a few locks and hasps. The main investment is the time to train people."
Despite the simplicity, low cost, and severe consequences of noncompliance, in 1995 lockout-tagout was the number one most frequently violated standard in several industries including food processing, textile mill products, paper products, and primary metals, according to Department of Labor records. Across all industries, OSHA cited employers for 4,728 lockout-tagout standard violations last year and issued more than $9 million in fines, making lockout-tagout one of the most expensive rules to violate.
For this article, ISHN asked a few area OSHA officers to explain why this straightforward standard is so hard to follow. They told us what mistakes they see leading to lockout-tagout violations in plants from Boston to Albuquerque, and offered suggestions for employers who want to get it straight.
Plainly put, the lockout-tagout rule (29 CFR1910.147) requires employers to isolate- and ensure continued isolation with a lock and a warning tag- all energy sources before servicing any piece of equipment or machinery to prevent startup while a worker is inside the machinery. The rule mandates training and training updates for every employee authorized to lock out machinery and every employee affected by the lockout- tagout program.
To be sure, typical lockout-tagout violations occur in plants where no program exists and no training has been conducted, says an area OSHA officer in New York (All OSHA officers commented not for attribution for this article). Some employers just don't bother. It's no surprise to inspectors when workers in those plants are injured, or worse.
For this article, we asked inspectors to talk about plants that do have programs and still fail to avert citations, injuries and fatalities. Weak supervision, ineffective training, and overlooking hazardous energy sources are the three main mistakes they point up.
Punish shortcutsEven well-trained workers seem to need the threat of disciplinary action to remember what they know about energy hazards, OSHA officers suggest. "I recommend a day without pay for workers who violate the rule the first time," says one inspector. After that, fire them, he says.
"A lot of times very intelligent people say, - I can get this done much faster'," says a New York area officer. "It's a matter of laziness: somebody doesn't want to go to the trouble [of following lockout-tagout procedures]."
Indeed, the company lockout-tagout program coordinator at an Albany area plant was killed recently when he shortcut the lockout rule.
"I told the new coordinator their enforcement policy was just not strong enough," says the OSHA officer who conducted the accident investigation. The new coordinator admitted it would have been tough to fire his good friend for not following the rule, but anything would have been better than having him dead, he told the OSHA investigator.
Stress the magnitude
Training that shows workers the destructiveness of hazardous energy is another key to compliance, say the OSHA folks. Workers who operate heavy machinery every day lose respect for the energy when they aren't reminded of what it can do.
"The main investment for compliance with this standard is the time to train people," says an OSHA officer. "And training definitely has to include a demonstration of the magnitude of the energy." He suggests using watermelons or orange crates to show the damage two pieces of metal coming together at a nip point can do.
Workers at a plant in the Hartford, Conn., area had a tragic lesson in energy magnitude recently: A repairman's skull was crushed when the machine he was under started up, according to the OSHA accident investigator.
Secondary sourcesA lot of people don't understand the standard despite its simplicity, says Charles Clarkson, operations manager for Dolan-Jenner Industries in Lawrence, Mass., and moderator for a recent National Safety Congress seminar on power press safety. "They don't understand the full scope in terms of energy: lockout-tagout is not exclusively electrical."
A Connecticut OSHA officer says people often forget about secondary sources of energy. "They'll lock out electrical and forget the thing has a hydraulic piston."
A New York area officer notes: "There are many sources of energy. Turn off the machine and lock open any electrical connection. Be sure all hydraulic pressures are relieved and all pneumatic or air pressures are let down. Any spring-loaded machines, and just gravity itself could be a killer. Block it up to make sure it doesn't come down on you. Don't forget thermal energy. There are some strange sources."
Key lockout-tagout provisions1. Training: Each worker involved and affected by these processes shall be trained initially and periodically. Employer shall certify that training has been accomplished and updated.
2. Program: The employer shall establish a program in writing and utilize procedures for affixing appropriate lockout or tagout devices, and to otherwise disable machinery or equipment.
3. Substantial: Lockout-tagout devices shall be substantial enough to prevent removal without the use of excessive force, tools, or accidental removal.
4. Identifiable: Lockout-tagout devices shall be identifiable to the employee applying the devices and warn against the hazardous conditions if the machine or equipment is energized.
5. Periodic inspection: The employer shall conduct periodic inspections of the energy control procedure at least annually, by authorized employees other than the ones utilizing the procedure being inspected, to ensure that the procedure and the requirements of this standard are being followed. The periodic inspection shall be designed to correct any deviation or inadequacies observed.
6. Energy isolation: Energy isolation shall be performed only by authorized employees.
7. Notification: Affected employees shall be notified by the employer or authorized employees of the application and removal of lockout-tagout devices.
8. Application of control: The established procedure for the application of energy control shall cover the sequence for machine or equipment shutdown, isolation, and manner in which the lockout-tagout device is affixed or used, and verification of isolation.
Source: New York Dept. of Labor