Writing Machine-Specific Procedures
Proper LOTO procedures result in increased safety and reduced costs.
- By Chris Rutter
- Mar 01, 2005
IN June 2001, a Marietta, Ga., worker was using his feet to tamp down cardboard inside a compactor when his feet became caught in the cardboard and he was pinned inside the machine. He was unable to remove his legs, both of which were severed above the knee by the machine when it unexpectedly restarted. OSHA fined the company a total of $140,000, including $70,000 for failure to use documented lockout procedures to render the compactor inoperable when employees entered the chamber to tamp cardboard. As this real-life example illustrates, effective lockout procedures can prevent not only worker injuries, but also hefty fines.
OSHA estimates 10 percent of industrial accidents are lockout/tagout (LOTO) related. These accidents are not only costly to the company in the form of fines and lost production; they also pose a serious threat to worker safety. Tragic accidents can, in many cases, be avoided by simply posting proper lockout procedures and making them accessible to all employees.
Because of the frequency and seriousness of these accidents, lockout/tagout is the most-cited OSHA standard for manufacturing. Moreover, a lack of procedures or inadequately documented procedures are among the most common violations cited by OSHA. This shows emphasizes the importance OSHA places on the use of standardized procedures in protecting workers from injury. In fact, OSHA inspectors are specifically instructed to look for documented procedures during lockout/tagout inspections. According to STD 1-7.3--29 CFR 1910.147, Inspection Procedures and Interpretive Guidance, OSHA inspectors are instructed to: "Ask the employer for the documentation including: procedures for the control of hazardous energy including shutdown, equipment isolation, lockout/tagout application, release of stored energy, and verification."
To stay compliant with the law, you must create and maintain machine-specific procedures. And as long as you have to do it, there are additional benefits to making the effort to create high-quality procedures. Creating good, effective procedures is a three-step process that includes:
1) Hazard analysis to determine the types of hazardous energy sources for each piece of equipment.
2) Identification of steps necessary to isolate and lockout that energy.
3) Creating documentation of hazard analysis results and plans to isolate and lockout energy.
Accurate, easy-to-follow procedures generate cost savings by preventing accidents and injuries to workers and damage to machinery. The National Safety Council reports the typical non-fatal accident costs on average $33,000, while a workplace fatality averages over $1 million including medical costs, worker's compensation, etc. Studies have shown that an effective lockout/tagout program can reduce accidents by 30 to 50 percent. Some insurance companies even offer lower premiums to companies that can demonstrate they have an effective lockout program in place.
Effective procedures also help to facilitate lockout activity. The procedure serves as a checklist that allows workers to move quickly through the list of steps without confusion or mistakes. Making lockout activities more efficient cuts downtime and production losses, thus boosting productivity.
What Makes a Procedure Effective
Effective procedures must inform workers not only what to lock out but also how to lock it out in order to create safe work conditions. Procedures must be written in sufficient detail so that all steps for shutting down, isolating, blocking, securing, and relieving hazardous energy are clearly covered. The procedures also must identify the specific steps for the placement, removal, and transfer of lockout or tagout devices, as well as the specific requirements for testing the equipment to verify it is in a zero-energy state.
Procedures must be machine-specific, meaning each piece of equipment must have its own procedure. More than one piece of equipment may share the same procedure only if 1) they have the same hazardous energy sources and 2) they have the same or similar methods for controlling that energy.
Making Procedures Easy to Follow
The key to writing good procedures is to make them as easy as possible to follow. Using a standardized format and including photos or pictograms with procedures can greatly enhance comprehension, thereby increasing the chance the procedure will be used and carried out correctly.
Standardized formats for procedures not only help to simplify the procedure writing process, but also help workers who may be responsible for locking out more than one machine. With a standardized format, workers are able to quickly scan the procedure rather than having to search for the necessary information in each procedure. A standardized template also make it easier to update procedures.
Photos and pictograms also help workers understand what and where specific energy points must be locked out on a machine. Using a photo of the machine with control points identified will give an overall guide to the various lockout positions on the machine. This makes locating parts easier and ensures the correct control points will be locked out. Visual identification aids help to speed the lockout process and eliminate guesswork.
In addition to the pictures, it is a good idea to label or tag the specific energy sources. OSHA standard 29 CFR 1910.303 says energy sources must be identified for purpose and magnitude (volts, PSI, etc.), while ANSI/ASSE Z244.1 expands this to include all types of energy points, electrical or otherwise. Energy-isolating devices such as valves, breakers, and disconnect switches that are located in the same area may be difficult to discern, and identification will decrease the likelihood of a lockout mistake.
Due to the nature of certain equipment, some procedures may become very long and complex. However, not everything has to be treated in one procedure. Sub-procedures may be used to make a procedure simpler and shorter. For example, a procedure may reference an operator's manual concerning shutdown operations. Information such as instructions for locking out commonly used valves also may be included in sub-procedures. While sub-procedures may simplify complex procedures, avoid using too many sub-procedures that require the user to reference another document because referencing too many may wind up making the procedure even more complicated and may make updating the procedure difficult. The key to sub-procedures is to make them as concise and clear as possible, while reducing the amount of information in the original procedure.
When You Don't Need a Written Procedure
In some cases, a written procedure is not necessary. Procedures do not need to be documented if:
- The machine has a single energy source that completely de-energizes the equipment to be worked on.
- The machine can be locked out with a single lockout device.
- There is no potential for the machine to store or re-accumulate energy during the shutdown period.
- There are no hazards posed to other employees.
- The machine has no history of lockout/tagout accidents.
In these cases lockout is still necessary, but a formal written procedure is not.
OSHA does not currently require documented procedures for minor servicing, but ANSI Z244 says, "when LOTO is not used, the alternative measures shall have procedures developed and documented."
Because most machine-related accidents occur when the machine is being cleaned or unjammed, "minor servicing" activities may prove to be the most hazardous. While it is not required by OSHA, having written procedures for this is a better option; having procedures for some machines but not for others can lead to confusion or no locking out being performed at all. Having a procedure for each and every machine not only reduces confusion, but also ensures all employees can have access to the lockout plan for each machine.
Sometimes it is impossible to have a documented procedure for each and every circumstance because as a procedure may vary based on tasks. In these cases, a work permit system may be best. Before a worker begins a task, a safety manager can perform a hazard analysis and document the safe work procedures in the work permit. This is a "just in time" procedure that is not done in advance and should be used only in situations where procedures are subject to change.
Ensuring Access to Procedures
Even the best procedures are of little help if employees do not have easy access to them. Once the procedures have been written, ensuring they are visible and accessible should be the next goal. Procedures should be easily accessible--for both the workers who need to lock equipment out and those who need to update procedures. The following four methods are acceptable ways to present lockout procedures:
- Binders. This is one of the easiest solutions for procedure storage. Binders can be kept in specially designated stations on the shop floor where all employees have access to it them when needed. In addition to being convenient and economical, binders allow all procedures to be stored together in a central location. However, binders may be cumbersome, and workers may have to search through the binder to find their procedure. Having one binder also means workers may have to wait if the binder is in use elsewhere, and that procedures might be taken out of the binder and misplaced or not returned.
- Online posting. This method allows you to update procedures as often as necessary and ensures workers have access to the most recent versions. Online posting makes procedures easy to access and print out, eliminates the risk of lost procedures, and makes them immediately available to everyone who needs them. However, workers must have access to a computer and printer; logging on, searching, and printing procedures may be a time-consuming task if the worker has not had proper orientation on how to access information online.
- Posting at or on the machine. Posting procedures at the machine ensures the correct procedures will be "right there" when needed. With procedures immediately accessible at each machine, workers should have no reason not to follow them.
- Attaching to work orders. Attaching lockout procedures to work orders can be done manually or with any CMMS program that will allow you to include digital attachments. When the work order is printed, the procedure is printed along with it. As with online postings, this allows the procedure writer easy access to the procedure for updates and workers have access to the most up-to date versions. However, not all maintenance tasks come with work orders, so there should be a backup way for workers to access lockout procedures.
Training and Auditing
OSHA requires procedure training for three types of employees: authorized, affected, and "other." Authorized employees are those who are performing maintenance and service work. They need to be trained on the specific skills and techniques to be used in the lockout activity, as well as undergo a review of the procedures and techniques annually. These employees need to be able to:
- Recognize hazardous energy sources.
- Understand the types and magnitudes of energy.
- Know methods for isolating and controlling hazardous energy.
- Know methods for the safe application, use, and removal of energy controls.
Authorized employees do not need to be trained on every procedure but must be familiar with a sampling of all of the different necessary techniques and skills that would be necessary. Authorized employees should also undergo a review each year to make sure they understand their responsibilities as required by lockout procedures. Affected and "other" employees do not need to be trained on specific procedures, but they do need to know the importance of the lockout process, how to recognize when lockout is in progress, and how not to interfere with the process.
Procedures must be audited at least once a year, and inspections must be done by an authorized person who does not normally use that procedure. The goal of the auditing process is to make sure each procedure is still providing effective employee protection. Procedures that are used less than once a year need to be reviewed only when used. Audits of procedures should be documented, including who, when, and what equipment's procedures were reviewed.
Workers and machinery are the two essential components in manufacturing, and keeping them accident-free should be a goal of any plant concerned about both safety and the company's bottom line. Lockout procedures provide invaluable information that could prevent a serious accident or save someone's life.
Having well-written, readily available lockout procedures for properly trained employees is the best way to prevent lockout accidents.
This article appeared in the March 2005 issue of Occupational Health & Safety.
This article originally appeared in the March 2005 issue of Occupational Health & Safety.