Beyond compliance: Overlooked aspects of lockout-tagout
Most industrial workplaces have some kind of lockout/tagout program in place. While OSHA Standard 190.147 is clear, there are many aspects to a properly functioning lockout program. A compliant workplace needs to guard against any potential gaps in safety protocol. This article looks at some aspects of lockout/tagout that could potentially be overlooked, including non-electrical energy sources, the use of machine-specific devices, and interactive group training.
The function of lockout/tagout is to control potentially hazardous energy. Electrical outlets and currents are the most obvious sources of energy in most workplaces. However, there are several other types of energy in most workplaces, and all must be given the same attention, precaution and care.
Kinetic energy is probably the most easily overlooked energy source. Kinetic energy is defined as any moving parts that can continue to move after the equipment is turned off. Belts, springs, and fans, for instance, often continue to move after the main electrical source has been turned off. It is imperative, then, that all kinetic energy sources be identified and included in all lockout procedures. When possible, potentially moving parts should be completely immobilized. Most kinetic energy can be dissipated by simply waiting for all moving parts to come to a stop. This is the safest method and is recommended whenever possible. Some machines may require a block or machine-stop to dissipate kinetic energy.
Gravitational energy can also pose serious safety threats. Potential gravitational energy refers to any elevated weight which could cause harm if not secured properly. When possible, all suspended parts should be lowered to a resting position before maintenance begins.
The most common lockout device is the lockout padlock. Most companies invest in padlocks, and most workers are trained to use them properly. However, there is a good chance that a given workplace will need significantly more than just locks.
Many machines require very specific ball valve and switch lockouts. These items come in a wide-range of sizes, so it is imperative to mark every energy isolation point and acquire the proper devices for each. It is important to note that there is no purely generic lockout procedure. Each lockout procedure must take into account the specific safety problems posed by a given machine. The solution will often require the use of specialized lockout devices.
Training should also entail hands-on experience with all relevant lockout devices. Given the variety that exists among lockout devices, it may not be immediately obvious how each device works. Workers need to gain proficiency applying their machine-specific devices properly before they begin day-to-day operations.
Interactive training, retraining and group training
Training must above all be specific. As we mentioned previously, there is no purely generic lockout procedure. While graphics, classes and supplemental materials are helpful and recommended, effective training should incorporate a worker’s actual experience. Training should familiarize workers with the devices and machines that they will be using on a day-to-day basis.
It is worth noting that industrial workplaces are highly interactive. Because workers use individual tags and lockout procedures have detailed requirements for individual responsibilities, group training can sometimes be overlooked. This can be a dangerous oversight. One negligent mistake from a single worker could potentially put several other workers in danger. To underscore the importance of group interaction and cooperation, group lockout training is recommended. Group training allows workers to experience something very close to an actual work environment, in which several workers are performing interconnected tasks. This helps workers become well-versed in lockout procedure and also sharpens crucial communication skills. This becomes especially important when using the group lockout method, in which working crews work under a single group lockout device.
Audit, enforce, communicate
Surveying the workplace and identifying all energy control points, acquiring all necessary devices and developing written lockout procedures are the first steps to creating an effective Lockout/Tagout program. Training, as we mentioned in the previous section, is the next step. A compliant lockout program, however, does not end after initial training. Audits and ongoing training are also a vital part of workplace safety and compliance.
New machines, new employees, and new devices necessitate retraining. In each of these cases, a potentially unsafe variable has been introduced to an already established lockout procedure. However, periodic retraining is necessary even if no new elements have been introduced to a given lockout program. All workplaces, even workplaces with strong written procedures in place and an experienced workforce, can experience lapses in protection. Shortcuts or forgetfulness can be as unsafe as a poorly-understood procedure. For this reason, audits are required by OSHA on at least a yearly basis. Audits should thoroughly document all involved workers, the date, and any discrepancies with the written procedure. This practice will give workplaces a historical and ongoing insight into their lockout compliance and performance.
Workers should be encouraged to voice any concerns or suggestions concerning lockout procedures. Open communication between management and workers is a critical component of a well-functioning lockout program. Improvements should not have to wait for yearly audits. The ideal lockout program is self-reflective and self-corrective.