Keep Plugging

LOTO success is all about persistence--and, in a sense, intolerance.

ALL or nothing: This is what lockout/tagout (29 CFR 1910.147 in the OSHA catalogue) comes down to. "You"--with a gesture indicating the newbies as well as the old hands at work, because you cannot cut any slack for experience--"you are in, or you're out. You are with us, or you're against us. There's no middle ground."

If presentations using phrases such as these are not the way you communicate about LOTO in your role as safety leader/director/manager, you're simply doing it wrong. You are failing to send the clearest and most essential message on this topic. I expect it is a message most of your employees instinctively understand.

An alleged failure to ensure that a qualified person confirmed equipment was de-energized before work commenced was part of a $431,650 penalty filed by OSHA just three months ago. While other alleged serious violations at that site involving machine guarding, molten metal, and fall hazards also figured into the high penalty assessed in the case, the size of the assessment is instructive: OSHA rightly takes LOTO violations seriously because they bring a high likelihood of major injury.

So when you orient a new hire or rise to conduct a weekly safety talk, you might ask your workers these questions: How many years will it take you to earn $431,650? How old will you be when you have $431,650 in savings? Or, you might try it this way: If our CEO opened an envelope from OSHA today and found a $431,650 penalty notice inside because you mangled three fingers in that press over there when I wasn't supervising properly, what do you think he'd do?

Inspections & Retraining
Hearing about real pain, both physical and financial, gets through to most of us. We understand those terms. But what you say may not be what your workers hear. Quizzes and refresher courses are a good idea to make sure procedures are well understood, while walk-throughs, audits, and observations can indicate how they diligently are carried out.

Routine retraining is vital to effective lockout/tagout. If it is done sporadically, with no real structure or schedule, you're in trouble. You should address emergency plans, first aid, and the tools of LOTO (locks, tags, valve covers, etc.) whenever a new machine is introduced into the workplace or maintenance work is scheduled.

Make a diagram showing the site's layout, work flow, machinery, and materials used. Among the items you should examine are locks, tags, and other LOTO gear; manufacturers' safety manuals, insurance or consultant audit records, relevant standards, and documentation of past lockout/tagout training sessions.

Familiarize yourself with maintenance logs and reports of previous incidents at the site. Don't stop when you've read the injury reports, however. Create a system that rewards employees for reporting near-misses. These can teach you plenty about hazard zones, leaks, and substandard work practices.

Checklist for Lockout/Tagout

The following checklist can be used in conjunction with your comprehensive lockout/tagout program. These items are not all-inclusive, of course, but are generally responsive to training needs and associated items.

Yes

No

During the interview process prior to hire, is safety discussed with each individual?

Yes

No

Is each interview candidate given a chance to express his/her attitudes on safety in the workplace?

Yes

No

Are prior accidents/injuries or property damage in the workplace discussed with each candidate?

Yes

No

Do employees repair or adjust equipment that is in motion, under pressure, or electrically charged?

Yes

No

Do they operate equipment at unsafe speeds or in violation of other established practices?

Yes

No

Are they using their hands rather than push sticks or tools?

Yes

No

Do they fail to use or maintain PPE and lockout/tagout tools properly?

Yes

No

As part of the reference review/interview, are the potential employee's attitude and ability toward safe work discussed with his or her references?

Yes

No

Are lockout/tagout and machine safety in general reviewed with each affected employee during new employee orientation?

Yes

No

Is regular job-site safety and health reviewed with new employees, including standard operating procedures for each machine to be used, maintenance activities, who their regular supervisor is, and how to report damage, unusual circumstances, and/or malfunctions?

Yes

No

Is training delivered on specifics of application and removal for each energy type for every machine or process to be used?

Yes

No

Are workers trained in first aid procedures, as well as the location of first aid supplies?

Yes

No

Are emergency notification numbers clearly posted and up to date for all employee areas?

Yes

No

Are employees advised of the consequences of not following approved guidelines and the steps involved toward termination?

Yes

No

Is annual training given as needed in those areas requiring it, or as new hazards are introduced into the workplace?

This checklist was compiled by Linda F. Johnson, a former technical editor of Occupational Health & Safety. It is not intended to substitute for a comprehensive safety program.

Clear & Effective Communication
In the end, it's part of the job for managers and supervisors to explain to employees what a machine-related injury really costs. Rushing and taking short-cuts can become habitual and seem harmless to some workers, but there is no second chance with energized machinery such as power presses, augers, and mixers. Share data on lost pay and overtime, higher insurance costs, and losses to the company. You must make sure workers understand they are risking their own lives and their families' livelihoods if they don't follow your rules.

Finally, document and discipline in response to every policy infraction, regardless of severity. The damage done by a single foolish mistake can be incalculable--and perhaps fatal or permanently disabling. No violations should be tolerated. Be consistent, be tough, and in this case, be inflexible.

This article originally appeared in the September 2003 issue of Occupational Health & Safety.

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