Process Automation and Lockout/Tagout: Finding the Proper Balance

This is the hard part, keeping the requirements in mind while also keeping your production humming along.

• By Jimi Michalscheck
• Jan 01, 2015

The decision was final, and the plan was to construct a new addition to help keep up with market demand. The senior leadership decided that moving the factory and building another factory was cost prohibitive, leaving the expansion as the best alternative.

This factory was built in the late 1980s and has been upgraded heavily with new switchgears and all new breakers that were a solution to help mitigate the arc flash dangers that existed with the old hardware. The factory was producing a very popular consumer product for which demand surges near the middle of the year, causing all of the technology to be utilized at full tilt just to make the quotas. This new expansion was a welcome addition.

As the planning committee gathered to start working out the details of the expansion, the room came to a hush when the CEO entered the room unannounced. "Today is an opportunity for us to reinvent the way we look at how we produce our product. I don't want business as usual here. I want to take advantage of the latest in technology to ensure we have the most efficient product lines per square foot that exist. Do you think you can do that?" The team hesitated, then one person spoke up: "Yes, we can."

What they did next was very important--they outlined key areas that caused their current product process to fall behind. The top two culprits were unscheduled downtime caused by jams, followed by scheduled downtime taking far longer than the predicted amount. The team realized that this finding would not only help them construct a better factory process in the expansion area, but also could be addressed in the existing factory lines.

Fast forward three years, and the expansion is complete.

The CEO enters the board meeting to report, saying production is up 400 percent from three years ago, and the company has additional capacity to increase its orders by another 100 percent before it needs to expand again. The CEO adds, the prior expansion was a success beyond what we could have predicted, and we are still analyzing the most important key contributors.

The board members start firing hard questions: What was the top contributor? Is there any worry about safety now that we are so much more productive with nearly the same amount of personnel as before? Have we done anything that has exposed us to risk with regulatory compliance?

The CEO takes a deep breath, contemplates his next move, and then faces them to proudly respond, "The old factory was improved most dramatically from streamlining the process involved when we have jams. Knowing jams would be unavoidable, our team developed two tiers of procedures. One procedure utilized the existing guarding and key off switches to perform minor maintenance and clear jams, while the other procedures that were for heavier maintenance or more critical jams were restructured to be more intuitive and easier to follow. While we made other improvements to the line as we analyzed the data pouring in from our productivity software, our team and I agree that the heaviest contributor to the factory's overall improvement was due to the improvement of our hazardous energy control program. The technology we use and the process we follow not only meets regulatory standards, it exceeds them. In fact we have not had a recordable incident related to servicing equipment in the last three years, which helps prove our point. It's faster and it's safer." The board members erupted in cheers and applause.

Analysis and Application to Reality
While this story might not completely mesh with the reality at every person's facility, the fact is, the tools they used for improvements apply to every company in every industry, even non-manufacturing businesses.

Hazardous energy control (lockout/tagout, as it's known in the United States) is a term used to describe the process that will protect employees when they are in harm's way of equipment movement when they are servicing it and unexpected start-up could cause injury or death. Lockout/tagout is on the top 10 list of most-cited regulations for all industries and is consistently the #1 most-cited regulation for manufacturers. So what are the requirements exactly?

That's the easy part. There are five components: Procedures, Auditing, Training, Policy, and Devices. That's also the order in which companies fail to meet compliance, with lockout/tagout procedures being the most-cited part of the lockout/tagout regulation, 29 CFR 1910.147.

The hard part is finding the balance by keeping the above requirements in mind while also keeping your production humming along. An overarching guiding philosophy for U.S. manufacturers is that with proper equipment, procedures, and training, a company should not need to use the OSHA-defined lockout/tagout process for most of the time. However, when there are not effective means by which to provide at least an equivalent level of protection for tasks that qualify under the 1910.147(a)(2) minor servicing exemption, lockout/tagout must be used. Some examples of industry best practices around alternatives to using lockout/tagout are:

• Standard operating procedures (SOPs). These procedures outline the necessary steps to take in order to ensure inadvertent reenergization does not occur while specific and routine tasks are taking place.
• Advanced machine guarding and process control. Well engineered and properly specified interlock guarding such as class III guarding that has been audited and tested regularly can provide a layer of protection that, when used in conjunction with training and potentially an SOP, will provide an equivalent or better level of protection, oftentimes with only seconds to utilize per cycle as opposed to several minutes as with lockout/tagout.

By understanding and utilizing the best technology available, as well as understanding and properly leveraging known regulatory exemptions where appropriate, a world-class high-performance production and integrated safety system can take place in businesses and factories where others thought it to be impossible.

There's a longstanding adage with safety: If's it's not easy, it's not safe. Meaning that if a program is designed to be too cumbersome to the process, people will find a work-around and eventually it will be less safe. Using that same mindset: Industry best practices have taught us that if it’s not efficient, it won’t last.

To learn more about how to engineer a lockout-tagout program in your facility that pays you back, visit www.escservices.com/learning-center.

This article originally appeared in the January 2015 issue of Occupational Health & Safety.