What stands out during the demonstration is this is the normal or routine way they perform their duties.
In the U.S., OSHA is very clear about what is required for a compliant Lockout/Tagout program since it remains a leading cause of many serious injuries and deaths across all industries. What I routinely hear from the EHS managers is the incidences of near misses or lesser injuries are under-reported. OSHA’s Control of Hazardous Energy 1910.147 (Lockout/Tagout) is one of the more complex compliance regulations the agency has promulgated, and it challenges employers of every kind to implement it effectively.
I find many companies we work with are driven to make the practice of lockout a competency rather than an obligation. Let’s look at some best practices to “normalize” the use of these protective practices day in and day out.
Sometimes we have to lock out, and sometimes we don’t
It’s common knowledge that some tasks that are routine, repetitive and integral to production are exempted from having to apply lockout measures. Often workers take liberties with this exception and remove guards or work in the hazardous action area of machinery solely under the protection of interlocks or e-stops. Rarely though, have I found the type of documented risk assessments ANSI Z244.1 recommends performed for these exempted tasks.
The value of these assessments is that they can clearly analyze which jobs meet the criteria allowed by the regulatory exemption, and when workers cross the line into mandatory lockout territory. Look for the updated ANSI Z244.1 standard coming out in 2015 to be much more detailed in describing alternative practices emphasizing safety rated circuit control practices.
Too many times safety initiatives get off to a great start and then lose effectiveness as time passes from all the implementation efforts it took to launch the program. So here are some common denominators I see in companies with highly functional lockout programs to sustain their day-to-day use of these protective practices.
Written lockout compliance programs
Assembled in user-friendly language with a clear and succinct method, it provides excellent material to train with. When questions come up about how some aspect of hazardous energy control should be implemented, the written program is the natural reference document. If it isn’t addressed in the program, the document gets revised after the new methodology is properly vetted and training takes place immediately.
Written machine- specific procedures
The best procedures are visual instructions with pictures and specific details of the isolation points provided for easy application of lockout techniques and posted on machines they are written for. Experienced personnel analyze any new piece of equipment and prepare a written lockout procedure on-the-spot prior to servicing or repair operations taking place.
All procedures are tested and signed off as being effective in producing a safe working condition. Log books or other records are kept at specific machines to document the frequency and duration of lockouts, so efficiencies can be studied and improvements made.
It always takes place before new hires go out on the floor and are either exposed to lockout situations or have to participate in a lockout as part of their duties. The best training occurs in the working environment with hands-on exercises after a base of regulatory requirements and the details of the company’s lockout program have been shared in the classroom. Practical skills include being trained from the equipment-specific procedures using the necessary devices to gain experience on how they are correctly applied.
A key sign of an effective training program is that it happens frequently throughout the year in small doses to update workers on new information, correct negative trends, address incidents, and keep best practices on workers’ minds.
What should be an ongoing function demonstrates to the workforce that correct practices are constantly being reinforced in the work environment. Rather than waiting for the one month of the year when annual audits of people and procedures traditionally get performed, let the process be a highly visible and common practice.
Divide authorized lockout personnel into unpublished groups and set a monthly schedule to get all of your people evaluated over the course of the year. Try to inspect during real applications of lockout instead of in a staged environment. Give immediate positive feedback and congratulate those who meet expectations. Privately correct those who fall short and then repeat the inspection process until they pass with flying colors.
Audit your written procedures using a technique that physically verifies that the written instructions will produce a fully controlled machine when correctly applied. Once verified effective by testing, use a Management of Change process that tracks modifications or movement of existing machinery and the addition of new equipment.
Access to equipment
Nothing frustrates workers more than not having tools available to do the best job. Strategically, follow lean manufacturing methods. Knowing what is needed to lock out a piece of equipment and that it is located steps away saves time. A 5S approach organizes the work area and puts what’s required to do the job within easy and consistent reach.