Controlling Hazardous Energy with Lockout/Tagout—Common Challenges and Best Practices

We have found that only about 10 percent of companies run effective lockout programs. In fact, we have observed that up to three-out-of-ten employers have no lockout program at all.

• By Todd Grover
• Dec 01, 2017

Workers began to specialize in operating and maintaining machinery in the Industrial Revolution. And quickly, consequences occurred: Those workers were increasingly injured or killed while servicing this equipment. This spurred improvement in the design of machinery to shield people from the dangerous work they performed.

The early efforts of the National Safety Council and similar organizations to raise awareness of the importance of machine guarding reduced the rate of accidents that were suffered while machinery was operating. But when these machine guards were removed to repair or service that equipment, a disturbingly high number of incidents continued to take place as equipment suddenly started up or released dangerous flows of energy, taking operators and other personnel by surprise. The American National Standards Institute (ANSI) began looking at these causes of injuries and fatalities in the 1970s and published its first guidance on controlling hazardous energy with the practice of lockout or tagout in 1982. The ANSI Z244.1 lockout standard became the inspiration for the OSHA regulation of 1989 requiring employers to put procedures in place to protect their workers by fully isolating machinery from the energy sources that drive them.

Despite the requirements of OSHA 29 CFR 1910.147 and other related federal and state regulations, incidents continue to occur at a pace that makes violations of the lockout/tagout requirements perennially one of OSHA’s most frequently cited regulations, as well as one of the costliest.

What Makes Lockout Compliance So Difficult?
Twenty-eight years after the OSHA lockout regulation went into effect, the law remains one of the most challenging for employers to successfully facilitate in their workplaces. From our years of field experience at facilities in many industries, we at The Master Lock Company have found that only about 10 percent of companies run effective lockout programs – defined as meeting or exceeding compliance requirements with lockout being practiced routinely each time it is indicated by the hazards of the tasks being performed. In fact, we have observed that up to three-out-of-ten employers have no lockout program at all.

The other six-out-of-ten companies find themselves somewhere in between. They may be in the initial stages of encouraging their employees to apply lockout when needed or improving the regularity of protecting themselves. Or they may have the goal of moving into the echelon of those top companies whose people routinely protect themselves when servicing machinery. Any time a company can pursue proactive, continuous improvement on a controlled timeframe, rather than as a reaction to a crisis, it is substantially beneficial to their bottom line and sustained profitability.

It's difficult for companies to routinely practice lockout because the OSHA regulation is very demanding and the sporadic nature of when lockout needs to be applied can cause significant logistical challenges. For instance, often only select authorized personnel receive the training and other resources to use lockout to protect themselves. Yet the need to apply lockout comes up frequently. It can be complicated by time considerations, insufficient numbers of trained personnel with access to accurate procedures describing primary and residual energy control measures, as well as the lack of quick access to safety equipment used to secure energy isolation devices, such as switches and valves. When we combine those factors with the challenge that sometimes energy sources must remain on to perform certain tasks, the variables combine to create confusing and conflicting messages to those tasked to maintain equipment. As a result, many managers and their workers believe lockout can impede productivity.

For the latest in best practice guidance on the control of hazardous energy sources, the ANSI/ASSE Z244.1 (2016) standard was updated extensively and provides the latest methodology and technological practices in a highly usable format that explains how to improve the facilitation of lockout, tagout, and alternative methods to control hazardous energy sources. Z244.1 (2016) is a must read for anyone seeking to improve their practice of locking out energy-related hazards.

So, Where Should You Start?
A common challenge companies face when seeking to begin or improve the use of lockout to protect their workforce is where to start. From the emphasis provided in Z244.1, the best way to begin is with a written plan of the lockout practices needed to achieve compliance—and then go beyond. A well-written lockout program serves as a user-friendly guide to implementation. It is also a benchmark for checking how lockout is really being performed, as compared to how it was planned to be applied. It is helpful to consult with knowledgeable safety professionals who have experience in establishing effective lockout systems. This can help set reasonable and measurable goals, such as timely and detailed training for personnel based on their level of participation in the lockout program.

Tiers of Authorized Training

• Machine operators and set-up specialists should focus on the basic practices of the company LOTO program with emphasis given to hands-on training with the limited number of machines they routinely work with.
• Supervisors can benefit from a more in-depth knowledge of the management responsibilities of the company energy control program and how to coach successful behaviors. They need more general knowledge on how a wider range of machinery under their oversight needs to be properly isolated and secured.
• Maintenance personnel often need much broader lockout training because they can be expected to deal with most, if not all, of the equipment under the company's roof.
• Electrically qualified personnel have special requirements for lockout identified in OSHA Subpart S.

Employers can receive assistance from organizations or individuals with educational design experience to develop useful and interesting training tailored to the needs of their personnel. Nothing seems as wasteful as meaningless, generic training that doesn’t provide workers the job-specific information they need to meet expectations and successfully apply that knowledge to protect themselves and others. The National Safety Council, State Safety Councils, local technical colleges, and dedicated industrial providers are excellent sources for both good content and instructional design and train-the-trainer programs to tailor lockout education to reflect the workplace needs and expectations. The Master Lock Company has routinely found the best lockout training programs are ones developed and presented internally by the employer. In fact, we have found the majority of demand for our Professional Lockout Services training is for our Lockout Tagout instructor courses and other training classes, such as Lockout/Tagout Alternative Procedure Writer Courses and Lockout Practitioner Certifications for management.

Does Lockout Impact Efficiency?
Three things are at the root cause of inefficiency when it comes to routinely and properly applying lockout/tagout. The first is absence of knowledge. If workers don't understand what could hurt them and the circumstances that could lead to unexpected startup, they can't appreciate the value of protecting themselves. They need good training and the guidance provided by accurate machine-specific lockout procedures to know how and why to protect themselves.

Second, if the culture of the workplace is to do whatever is necessary to get the job done, workers must decide in each situation whether the time to apply lockout is justified. Unfortunately, the statistics support they often make the wrong decision, taking dangerous shortcuts. My experience is the more practiced a worker is with the skill set of lockout, the faster and more consistently he will apply it. It becomes the normal way to perform a task and is done consistently the right way.

Third is the lack of necessary resources. If lockout procedures are not readily available to reference or hands-on, machine-specific training is not provided, errors are very likely to be made. When all of the needed lockout equipment is not immediately available, chances are workers will think twice about going to get the safety devices and locks required for the task. If there's insufficient lockout resources or guidance from company leaders, employees may believe that unsafe behaviors are tolerated, if not encouraged.

The severity and related costs of lockout-related accidents are undeniably high. When these root causes are effectively addressed, protective practices flourish and are used frequently. They become the rehearsed and routine way of performing maintenance, repairs, cleaning, troubleshooting, and set-up activities.

Simply put, it's a new age. At the time the first ANSI Lockout/Tagout Standard and the OSHA LOTO regulation came out in the eighties, there was a lack of lockable energy isolation devices and no aftermarket lockout devices to add lockability to equipment of that era. Alternative methods to lockout were poorly understood and usually undocumented. These days, virtually every type of machinery, including those from foreign sources, is much more likely to be equipped for lockability or can easily be retrofitted with effective aftermarket lockout devices. Alternative procedures involving partial lockout and additional control methods can be successful at providing a safe way of completing tasks when energy must be present.

Getting companies and their workers engaged in a best-practice approach to using lockout to control hazardous sources of energy is all about planning, implementation, and a culture that believes working safety is more than a sound business decision. It's a way of life.

This article originally appeared in the December 2017 issue of Occupational Health & Safety.