The 'Maintenance Guy's Standard'
I often explain that LOTO is just like any other safety or machine guard: It only works when in place.
"GETTT iiittt done," one of our maintenance fellows good-naturedly growls at me as a "good morning" comment almost every day as he makes his job list for the day and walks a multi-story construction project in the pre-shift quiet. It seems to be the unspoken slogan for most maintenance men, from entry level to advanced engineers.
Whatever the job, they move to it, through it, and on to something else as quickly as possible. "Get it done" means working around problems as quickly as possible with as few headaches as he can manage. My response is usually: "Safely!"
Electrical, machinery use, repair and upkeep, construction, plumbing, general repair . . . whatever needs to be done lands on their ever-growing list. Most maintenance workers are a pretty versatile breed. Each is the eyes and ears of the company and knows just about everything going on. They move from task to task with a wide range of common sense, craft knowledge, and luck, often working with less than a full set of tools, education, training, or help on hand. They are task oriented and often with a short attention span because of the huge list of "to do" that management says must be done today (if not yesterday) for the work to continue.
How does lockout/tagout fit into this? Many of us think of LOTO as a "big company" standard that takes up a lot of manpower and production time, which is not the case. Few OSHA standards are as lifesaving as the control of hazardous energy (lockout/tagout). Lockout/tagout failures result in horrifying injuries and fatalities: crushed and mangled body parts, charred remains after electrical contact, thermal burns, or being struck or impaled when a machine is started up and tools or other debris is slung, striking a worker.
The sad news is that for every reported death or injury, there are hundreds of near misses never heard of. As human beings we do not like to admit mistakes, so often the near misses of LOTO are downplayed or not spoken of, instead of being used as a learning tool to prevent them from happening again. There are few original injuries with failure to use LOTO; the injury type happens over and over, such as being caught in, under, or between or being struck by a machine part when the machine starts up and the employee is still in the danger zone. And if LOTO had been used, a needless occupational death could have been prevented.
Rather than a "big company" standard, LOTO is a "maintenance man's" standard because he so often works either alone or with one other person. It is a standard that specifically protects his/her life each and every time it is used. I often explain that LOTO is just like any other safety or machine guard: It only works when in place.
Program Elements for Special Situations
There are many struggles in the maintenance shop application of lockout/tagout. Putting into place a policy is only the beginning step, along with posters or other useful printed or computerized or video training items. The most important part of the program is getting the workers to understand the need for and to actually use LOTO consistently. That is a huge hurdle to overcome, especially in smaller shops.
The smaller work groups will rarely admit any problem to management, including a failure to understand procedures. Invisible because of small work numbers at different facilities, they try to work it out on their own as best they can.
Another important program element is the update of a program. If new workers or interns or temporary employees are in the shop and have not been trained on LOTO use, your system has failed. If new equipment is in use that does not have procedures documented and communicated, you have just put every employee's life on the line.
Sharing the LOTO Responsibility Fairly
You as management provide the training and a written policy, then focus on the next program or project with an assurance that all is well. Unfortunately, too often management and safety professionals are shocked and dismayed when a lockout/tagout accident occurs in their shop.
During an accident investigation, rolling out pages of signed training forms may not be enough to ward off citations if the application was not used. Herewith the lesson: Management must enforce and follow up on workers' use of LOTO. The program must work, not just exist.
Training Proficiency for LOTO
You may have pages of training documentation, videos, and interactive items to dazzle inspectors; but when it comes to knowledge, do your employees really understand what lockout/tagout does for their personal safety? If you get a blank or befuddled look when you ask employees to tell you what lockout/tagout is and the last time he/she used it, your program is a failure and employees' lives are in danger. (That is a pretty serious statement to make--serious and true.)
There are few second chances with lockout/tagout failures. Even a near miss means adequate safeguards and procedures were not used appropriately. Not updating the program on a regular basis is a program failure for many small shops. New equipment or new uses of old equipment mean new or better procedures need to be implemented. Training means "to make proficient," which is a high level of understanding. Do your employees understand how to apply LOTO procedures and get the work done, and do they know that if it takes more time, that's OK?
Are they proficient in LOTO? Have you as management ever asked that question? You may be surprised at the answer you get!
The Hardware of LOTO
Do you have those necessary items to make LOTO successful? These include training "how to's," as well as locks, hasps, kits, wall centers, tags, chains, cable lockouts, pneumatic lockout devices, group lockout items, gate and ball valve lockouts, and wall switch, circuit breaker, and electrical plug lockouts. If you can think of it, a product to lock and tag it correctly is available.
A more important question is, are these items new and shiny (or still in the original packaging)? I recently saw a beautiful lockout wall kit at a company auction, still wrapped in original cellophane that was more than 14 years old and never had been used, not even once. If the item is more than a few months old and still new and shiny, chances are it is not being used other than for window dressing.
If you pick up any LOTO item and hand it to an employee who is supposed to use such tools, can he or she identify it and show you how it is used? Can he or she do this quickly and correctly without prompting?
Hazards of a Static Program
You see it a lot: a canned training program handed to employees and forgotten about by upper management. They're rolled out once a year for training and then not thought about again.
Making any training program meaningful and applicable to your employees and work situation is the make-or-break part of a useful program. Allowing employees the opportunity to ask questions of someone who knows the answers and ensuring each employee fully understands specific procedures are the best way to have a successful program that will be used. For those gray areas, retrain employees on LOTO procedures until they understand. For many it is uncharted territory, and many employees feel LOTO wastes time.
It is your job as the safety professional and as management to instill in them the need to use LOTO to protect their lives and protect their jobs. If you consistently have an employee who fails to use LOTO, get rid of him--because he is a huge liability to your company. There is no such thing as a "cheap" fatality or worker's comp claim.
2005 Lockout/Tagout Checklist
Lockout/tagout violations can result in horrific injuries or death to employees and are often cited by OSHA after an accident. Be proactive! Dust off your copy of the standard and your program and evaluate it thoroughly in order to ensure worker knowledge and safety.
While no checklist is a substitute for a comprehensive program evaluation, use the following as a quick reference for problem areas to concentrate your time, including:
* Are all energy sources documented on site? Are employees specifically informed of the various energy sources and potential hazards associated with them?
* Do you have on site and available to all employees who need access a complete set of lockout/tagout hardware?
Are all items in good working order and appropriate for your operations? Are missing or damaged items replaced immediately?
* Is a current copy of your policy and procedures available to employees?
* Are these items updated on a regular basis by someone qualified?
* Are employees provided quality training materials and provided the opportunity to ask questions for clarification?
* Is all machinery or equipment capable of movement required to be de-energized or disengaged and blocked or locked out during cleaning, servicing, adjusting, or setting up operation?
* Where the power disconnect equipment does not disconnect the electrical control circuit, are the appropriate electrical enclosures identified?
* Where the power disconnect for equipment does not disconnect the electrical control circuit, is a means provided to ensure the control circuit can be disconnected and locked out?
* Is locking out of control circuits in lieu of locking out main power disconnects prohibited?
* Are all equipment control valve handles provided with a means for identification and locking out?
* Does the lockout procedure require that stored energy--whether it is mechanical, hydraulic, or air--be released or blocked before the equipment is locked out for repairs?
* Are appropriate employees provided with individually keyed personal safety locks?
* Are the employees required to keep personal control of their keys while they have safety locks in use?
* Is it required that only the employee exposed to the hazard install or remove the safety lock?
* Is it required that employees check the safety lockout by attempting a start-up after making sure no one is exposed?
After the safety is checked, is the switch again placed in the "off" position?
* Is there a way to identify all employees who are working on locked-out equipment by their locks or accompanying tags?
* Are enough accident prevention signs, tags, and safety padlocks provided for any reasonably foreseeable repair emergency? Are they used?
* If the equipment or lines cannot be shut down, locked out, and tagged, is a safe job procedure established and rigidly followed? And is the person in charge of this operation established?
* Have employees been trained not to start machinery or equipment if it is locked out or tagged out?
* Are all workers notified when the machinery or equipment they usually use is shut down and locked out for maintenance or servicing purposes?
* After maintenance is completed, is the machinery checked to ensure non-essential items have been removed and the machine is operationally intact?
* Before the machinery is activated, are employees, vendors, visitors or other inspectors removed from possible danger zones?
* When the machinery is fully operational, are employees notified?
* Are near misses reported to management? Are these followed up and corrected to prevent recurrence?
* If your facility utilizes subcontractors, temps, or interns, are they trained and advised of your policy and procedures?
This article appeared in the September 2005 issue of Occupational Health & Safety.
This article originally appeared in the September 2005 issue of Occupational Health & Safety.