- ISHN GLOBAL
- EHS RESEARCH
Four words — variable conditions for shutdown — relating to compliance in OSHA safety regulation 1910.147 regarding the control of hazardous energy (lockout/tagout), have enormous meaning for virtually any facility and anyone responsible for worker safety. OSHA requires separate lockout-tagout (LOTO) energy control procedures for individual machines that fit this description — every single one. Not only production equipment, but also pumps, boilers, air handler units, hot water heaters, you name it.
This can pose serious challenges beyond the number of machines involved, because “variable conditions for shutdown” covers multiple energy sources (electrical, water, gas and steam) and/or different power connections (circuit breaker, valve and plugs) and control procedures.
Recent headlines regarding OSHA actions following the death of a worker at a New England food plant remind us that, even with contract workers brought in for cleaning or other tasks, the facility employer is still responsible for providing proper LOTO procedures, reviewing procedures annually and training personnel to utilize them.
“Clear steps, clearly understood”
The goal for any lockout/tagout procedure is to provide “Clear Steps, Clearly Understood,” so that a worker who is not familiar with a machine can quickly and clearly understand what needs to be done and perform the tasks safely.
This is why simply writing “procedures” isn’t enough. Even if instructions correctly itemize machine control procedures and lockout steps, a lengthy type-written document that requires close scrutiny isn’t always very practical on the real-world plant floor.
“Show-and-tell” visual lockout procedure placards located on or next to each machine can clearly indicate energy sources that need to be locked out, the lockout points, the steps required and the LOTO devices needed. Visuals may also help to overcome language barriers — at least to some degree — when dealing with a diverse workforce.
This is why compiling photos, for example, is a key task during the initial equipment audit (see “Developing Visual Procedures” below). Including pictures of key areas around the machine on the LOTO placard shows workers what to look for. ID tags on the machine call attention to lockout points for various energy sources.
Procedure placards need to spell out actions required to address each energy source. One excellent approach is a color-coded chart using red, for example, for electrical energy sources, green for water connections, white (with red type) for steam, and so forth. Purple could call attention to kinetic and/or thermal energy issues that require workers to wait after other energy sources have been shut down before proceeding with maintenance activities. Use the same colors consistently for each energy type (e.g. electrical), and colors for energy-source ID tags on the machine should match those on the placard.
When properly done, visual procedure placards give workers a comprehensive yet compact, easy-to-follow checklist for safely performing lockout tasks.
Specialists can help
All that goes into such visual lockout procedure placards doesn’t happen by accident. Machine-specific procedures first need to be spelled out, and there are multiple steps to placard installation and maintaining your ongoing LOTO program.
Many firms turn to professional safety consultants for developmental help for several reasons. While you or assistants may face time constraints and be pressed by other tasks, the consultants’ focused responsibility virtually ensures rapid progress. Look for a full-service provider who is well known in industry and up-to-speed on all aspects of safety lockout-tagout.
Why “full service”? Whether they handle all or portions of your procedure development and implementation, full-scope familiarity will help ensure that all items are systematically covered.
Developing Visual Lockout/Tagout Procedures
1. Audit all current equipment, lockout processes and energy isolation points (compiling photos as well as data is part of this step)
2. Write specific procedures for each machine
3. Obtain management approval
4. Produce training materials
5. Produce visual lockout procedure placards and machine-specific lockout isolation ID markers
6. Install procedure placards along with the isolation ID tags at each machine’s lockout points
7. Procure lockout devices and padlocks identified in the procedures
A full-service firm will provide a manual with a complete paper version of program material. Some also include a CD with your manual, which enables you to update procedures for new or existing equipment at any time.
Again, you may choose to do all of this on your own, or hire a consulting firm for portions. What matters is that it gets done and fully complies with OSHA regulation 1910.147.
Keep procedures current
Several companies also offer Do-It-Yourself (DIY) software for developing and updating your own procedures. If considering this option, look for software that is non-proprietary and is backward and forward-compatible, so you won’t have to buy new software when it’s time to update.
Placards themselves and ID tags must be able to withstand plant environmental challenges (chemicals, water, dirt, grime), not scratch or tear, and be UV-resistant to prevent fading. Lamination is a plus. Better yet, look for placards where information is fused into the plastic material itself. They are virtually indestructible and easily maintained.
Bottom line: LOTO’s purpose is to avoid injuries, damaged equipment and/or OSHA citations, while also reducing time spent on machine maintenance/repair, with additional ROI from increased equipment uptime and production. Properly prepared and located visual lockout procedures can help you accomplish all of that, every day.