How to Make Your LOTO Program Pay You Back
Many businesses think they are compliant, when in fact they are not. The number one most commonly cited part of the lockout/tagout regulation is lack of machine-specific procedures.
As the digital chime indicated shift change, the first shift's employees filed into the locker room to change out of their work clothes and head back home. Stanley, a 30-year veteran of his trade and an authorized employee, had about 10 minutes of service to do before finishing for the day, so he decided to finish up before leaving to help the company get more output.
He had followed the graphical lockout/tagout procedures the company provided, dissipated all of the thermal energy coming into the press he was servicing, and correctly restored it to energy, taking care to be safe and follow the company's policy when he put it back in service. When Stanley completed his service, he removed his locks and went home, knowing he'd done his job safely and effectively.
Or did he? Stanley failed to notify the press operators that the press was ready to operate, which caused the next shift's operators to wonder whether he was finished with his work or not. There was no way to tell just by looking at the press whether it was completely ready to run. To to be on the safe side, the operators opted not to run the press. Consequently, the press stayed out of production for the entire shift, which cost this company more than $100,000 in lost output.
While nobody was hurt with this simple oversight, it's a good example of how an improperly executed lockout/tagout program can impact that company's bottom line in a big way. Having a non-compliant or outdated lockout/tagout program can cost your company money in more ways than just OSHA fines.
So what are the basics when it comes to implementing a high performance modern lockout/tagout program? First, you need to understand the program is not something that you can just purchase, throw on a shelf, and ignore until it's time to use it. It has to be treated as a dynamic program that involves communication and corroboration between employees on the floor and employees in upper management.
OSHA put the federal standard, 1910.147, in place in 1989. Since that time, the purpose of lockout/tagout has remained the same while the equipment has grown enormously more complex. Back when the regulation was written, complex PLC linked interlocks, remote computer controls, light curtains, automatic valves, and other such commonplace automation accessories were not as common or did not exist. Now, this argument exists: "Why not just rely on a PLC control lock to easily lock out the air, water, gravity, and electrical while I perform the service work?" Unfortunately, some companies have tried this and paid the ultimate price when a worker got trapped in the equipment because of residual energy or equipment malfunction that resulted from improper lockout. PLC soft locks do not offer the equivalent protection of a physical lockout, so OSHA does not allow this as a zero-energy state solution.
There are five main elements every program needs to ensure it's not only OSHA compliant, but also remains effective and efficient. Those elements are:
- Corporate policy
- Machine-specific procedures
- Locks, tags, devices
- Annual auditing
Current Status Quo
Lockout/tagout still remains on the top 10 list, as it has for more than 15 years now. For the manufacturing sector, it is still the most-cited OSHA regulation. All told, LOTO violations cost U.S. companies nearly $8 million every year from both state and federal OSHA citations combined, and that's just the citations that resulted from accidents or investigations. The improperly executed LOTO program that leads to an accident can have more immediate and lasting effects, from equipment downtime and lowered employee morale to civil lawsuits, workers' comp claims, and increased insurance rates.
Many businesses think they are compliant when in fact they are not. The most commonly cited part of the lockout/tagout regulation is lack of machine-specific procedures. If your company doesn't have machine-specific procedures (and by that, I mean a procedure that was developed specifically for each piece of equipment), you run the risk of a $70,000 fine for each missing procedure. That can add up very quickly.
1. How many employees do you have?
With experience creating more than 100,000 machine-specific lockout/tagout procedures for hundreds of companies around the world, we have accumulated data that helps us give guidelines to our clients to help them perform a quick checkup of their lockout/tagout programs. Most program non-compliancy can be easily found out in three steps:
If you are in the manufacturing industry, have you located all of your equipment? To calculate the approximate number of pieces of equipment needed, use your employee count. This number could vary depending on your specific business setup, but generally speaking, we've seen a ratio of at least 1:1 between how many pieces of equipment exist in a facility and how many employees are present at that facility. Again, it's not a final factor, but it's a starting place. If, for instance, you know that you have 30 procedures for your lockout/tagout program, but you have 250 employees, you may want to re-evaluate your program to ensure you are not missing equipment.
If you're in the hospital industry, another corresponding 1:1 ratio is the number of beds a hospital has. Again, it's not always exact, but there have been a high number of hospitals that have a 1:1 ratio of number of procedures with number of beds they support. For instance, a 500-bed hospital is likely to need 500 lockout/tagout procedures for its equipment. This comes as a surprise to many facilities who thought their general LOTO procedure was good enough for all of their equipment.
2. Have you audited your program in the past year?
If it has been more than three years since you audited your program, you may want to consider creating a new program from scratch. Saving an old program that has an inaccuracy of more than 50 percent is sometimes more difficult than removing all of the procedures and creating new ones from the existing data. OSHA requires an audit every year to help ensure any equipment changes or deficiencies are caught before they become an accident. The federal and state OSHA requirement for all of the United States is that every procedure is reviewed at least annually to ensure compliancy and accuracy. When companies have a change rate of 5-10 percent or more annually, it doesn't take long for the whole program to become worthless if it is not kept up correctly.
3. Have you provided and kept track of your training and employee annual auditing?
OSHA requires that authorized and affected employees be trained on lockout/tagout. Additionally, OSHA requires that they be tested at least annually to ensure they comprehend the proper use and application of the lockout/tagout rules and procedures.
Make the high-performance program pay you back
The bad news may be that you just discovered you are not compliant, but the good news is that there are many new uses of technology to make your job easier. Here's a list of ways to get your new program up and running quickly and efficiently:
- Digital picture-based graphical procedure. Utilizing a high-end digital camera will give you the best results. By using high-resolution images in your procedures, you are eliminating much of the time it takes the authorized employee to read the procedure because he or she can graphically see what the equipment is and where the isolation point is located.
- Ruggedized placard for the procedure. Many sign and label companies make products that can withstand most environments, even outdoors and in washdown areas. While the placard may vary in cost (from the heavyweight laminate for a few dollars to the top-of-the-line injection molded procedure for around ten times more), the investment will pay off when your authorized employees don't have to hunt around looking for the procedure when they are trying to lock out a piece of equipment. It also helps with auditing to have the procedure mounted right at the point of use on the equipment.
- Graphical energy source ID tags. Many custom sign shops can make just about any tag you want. Engraved plastic, stainless steel, or, if you want the best of both worlds, injection-molded polypropylene color tags mounted with a stainless steel tie. The point is no matter what you choose, utilize a graphical tag to mount at each energy source to help the authorized employee speed up the lockout/tagout process without compromising safety. An example of utilizing graphical tags: If you have a primary electrical source for your equipment, mount an E-1 tag right at the isolation point. Now your graphical procedure shows the authorized employee where the isolation point is, and the graphical energy source ID tag also indicates where the disconnect is by displaying "E-1" right on the disconnect itself.
What You Can Expect
If you had no program or even an outdated, text-based program, you can expect to see dramatic results from upgrading your program to a graphical based system. Through studies performed for our clients, we have seen efficiency improvements of more than 80 percent when compared with an existing, all-text-based procedure. This means that if the company was spending 100 hours a month locking equipment out and restoring it to service, it could easily reduce that to 20 hours per month. If the hourly rate were $30/hour, the company just saved $2,400 per month, or nearly $30,000 per year.
How to Implement
Now that you know what you need, how is the best way to get it? There are many ways to implement a new lockout/tagout system. If you are a very small site with only a dozen or so pieces of equipment, then it might be best to just create them in house. It will take some time to get a format that you like, but just use MS Word or MS Excel to create your procedures. It will ensure they are easy to use and modify for years to come.
If you have a more moderately sized business of 50 or more pieces of equipment, it may be best to consider outsourcing your program to a company that specializes in this service. Many companies offer lockout/tagout compliance assistance, so be sure you choose the company that has experience in your industry and understands all aspects of lockout/tagout compliance, not just labeling or locks. By choosing a company to create your program for you, you will be assured accuracy and compliancy quickly and effectively so you can start realizing the benefits of the high-performance system in weeks versus years.
Lastly, after implementing your program, ensure its longevity by properly training and auditing your employees and procedures. In the example at the beginning of this article, if Stanley were properly trained, he would have understood that once he was finished with removing his locks and tags, he was obligated to notify the affected employees that it was safe to resume operation. That simple act would have saved his company a bundle.