Lockout Leadership as a Path to Advancing the Practice

It is much more effective to share with workers the ways and means the company has decided to do things, rather than let impersonal government regulations drive critical behaviors.

• By Todd Grover
• Mar 01, 2018

Since the inception of the practice of lockout/tagout dating back to the first ANSI standard on the subject issued in 1982, controlling the release of hazardous energy has addressed a need while also created challenges. Without securing machinery to prevent sudden startup, workers focused on the task at hand have little chance to react if their actions or the decisions of others cause dangerous machine activity to occur. The challenges are to engage those workers in understanding their exposure, consistently taking the right precautions, and watching out for others who could be hurt by their actions.

The OSHA Lockout regulation, particularly as it is laid out in detail found in CPL 0200147 Enforcement Policies and Inspection Procedures, creates obligations for employers to follow. Yet, 29 CFR 1910.147 violations consistently rank among OSHA's most frequently issued citations every year. Again in 2017, OSHA ranked lockout as number 5 in the Top 10, with the following areas being cited most frequently:

• 1910.147(c)(4)(i)—Failure to provide Energy Control Procedures
• 1910.147(c)(1)—Failure to have or follow the required Energy Control Program
• 1910.147(c)(6)(i)—Failure to perform Periodic Inspections of energy control procedures
• 1910.147(c)(7)(i)—Failure to Train or properly Communicate lockout skills and requirements
• 1910.147(c)(7)(i)(A)—Failure to prepare workers to recognize applicable hazardous energy sources

Madness is artfully described as continuing to do the same thing but expecting to get different results. So unless we advance our lockout practices, we can expect to see lockout again in 2018 and beyond ranked as number 4 or 5 in the Top 10. Because all the rules, engineering methods, lockout devices, and various training programs already exist but are falling short of effectively solving the problems, enhancing engagement at all levels of employment is a viable solution to drive better practices going forward.

Using Safety Champions
A Safety Champion Program is not a new concept. The companies that use Safety Champions effectively send a clear message from management to workers: "We believe that it is important for you to go home healthy at the end of the day. To assure this happens, we are going to make safety a part of everything we do and get everyone involved in making it happen." These programs are often very broad in scope and focus overall on better preparing workers to succeed, empowering change to address hazards, and involving personnel at all levels to improve the safety and productivity of the workplace through their participation.

A leadership program can be the connection between a well-done administrative program and the reality of how the work is performed on the plant floor. Lockout leadership is based on a mentoring approach that succeeds because it establishes these critical protective practices as the normal way jobs are performed, rather than an extra and sometimes optional safety step. The program looks like this:

The company's written lockout program should be designed as a guide that describes what good lockout practices are intended to look like specific to the facility. Responsibilities at each practical level are well defined and lockout leadership is added as a role. By turning the program into a user-friendly tool, it can be used as the basis for training workers rather than the common focus of OSHA regulatory requirements and misapplied exceptions. It is much more effective to share with workers the ways and means the company has decided to do things, rather than let impersonal government regulations drive critical behaviors. Of course, the user-friendly program takes into consideration all the regulatory requirements and has worked them into the methods shared during training and practical applications.

Classroom lockout training for authorized personnel, often provided by safety and health personnel, focuses on company expectations from the written program; roles and responsibilities; demonstrations of practices common to all, such as lock color schemes and assignments; and tagging methods. This is also the time to explain the role of lockout leadership in supporting the use of energy isolation procedures, alternative methods, periodic auditing, and a ready resource for ensuring best practices. Upon completion of the classroom portion, class participants are introduced to their respective Lockout Leaders, and the hands-on portion of training begins.

Lockout Leader Qualities
So what exactly is a Lockout Leader? They are specially prepared advocates that are part of a "Lead by Example" program for consistently using good lockout practices whenever sudden startup or release of energy could cause an accident. These leaders are hands-on trainers for the machinery in their assigned areas. They are recognized as friendly resources for lockout information, the eyes of the lockout program to reinforce good practices when observed and correct insufficient practices when noted. They often are the periodic inspectors of authorized personnel and equipment-specific lockout procedures in their assigned work area. As part of the inspection process, Lockout Leaders are likely to be the verifiers of new or modified machinery in their area to be sure new or updated lockout procedures will fully isolate the equipment before it goes into service.

Who commonly is involved in the Lockout Leader position? Geographic or functional areas of the facility are established and often led by operations and maintenance managers, foremen, lead people, safety committee members, and experienced authorized personnel who know the machinery and processes and have demonstrated their commitment to routinely work safely. To get full engagement from the people willing to serve as Lockout Leaders, it is important to discuss that they usually are not enforcers of rules or behavioral critics, as this can discourage their interest in participation. Instead, they are most effective as role models and mentors that positively affect the adaptation of routine and thorough use of energy control practices. Disciplinary action for intentionally and/or repetitively disregarding the guidance provided by Lockout Leaders is provided by the offending worker’s direct supervisor per usual channels.

Lockout Leaders need to be seen in a positive role by consistently demonstrating good lockout practices in their personal work. They enjoy sharing best practices in one-on-one interactions and welcome inquiries for more information or necessary resources like procedures, training, lockout devices, or improvements to machinery. They notice and congratulate good lockout performance on an ongoing basis. And they confidentially coach deficient performance and recognize conditions when injuries could be a consequence of not locking out. They often use inspections to document good performances and corrective actions on an ongoing basis.

As an illustration of the contributions of a lockout leadership program, let's look again at the most often cited OSHA violations that lead to the serious accidents we all are trying to avoid.

• Energy Control Procedures—Lockout Leaders know the equipment in their assigned areas and make sure existing lockout procedures are accurate and well understood during hands-on training. Deficiencies are reported to management for corrective action.
• Energy Control Program—Lockout Leaders know how to apply the facility’s program to the work being done in their respective areas and use their knowledge to train others and lead by example.
• Periodic Inspections—These get performed in real time as a part of safety observations by the Lockout Leaders. This makes inspections a routinely occurring activity that reinforces effective performance and corrects poor performance. Not only does the quality of the inspection outcomes improve, but the division of this responsibility over several qualified Leaders ensures that inspection goals can be met as a leading-edge indicator of good safety performance. This contrasts with the current practices often seen in workplaces of inspections never getting done or being performed as a flavor-of-the-month activity that adds little or no real value to actual energy control practices.
• Training and Communicating Lockout Skills and Requirements—Now you are blending good, to-the-point classroom guidance with effective and ongoing hands-on training. With a readily available local resource to answer questions and provide ongoing guidance, workers are better prepared from the start to meet their responsibilities and can easily access a nearby Leader to ask for advice or address their lockout concerns.
• Recognizing Applicable Hazardous Energy Sources—It’s one thing to talk generally about the myriad of workplace energy sources in a classroom setting. It is yet another to have a knowledgeable Leader show the potentially exposed workers where they exist and how to control them on a machine-specific basis.

Lockout leadership can be the missing link that drives continuous improvement leading to meaningful change in the safety culture of the adapting workplace. It can meaningfully engage people on all levels to understand upper management's intentions and commitment to provide the needed resources, and it can be incorporated into the day-to-day challenges workers face performing their tasks. Lockout leadership is key to changing lockout/tagout from being the extra step into the normal way of safely and effectively completing potentially hazardous job assignments.

This article originally appeared in the March 2018 issue of Occupational Health & Safety.