How to Refresh Your Hazardous Energy Control Program and Make It Last
For any safety manager who wants to see whether his or her company might benefit from a refresh of the existing program, a good first step is to seek out professional assistance to learn more.
Every company is unique, yet they all have the same OSHA regulation to comply with when it comes to hazardous energy control, commonly referred to as lockout/tagout. Outside the United States, the global trend for hazardous energy is parallel, with patterns developing where companies are choosing to look at their lockout/tagout program again and reinvent it for various reasons. One scenario that commonly plays out is when a growing company decides to hire a full-time dedicated safety manager. Oftentimes, the expectations are that this new manager shall ensure the safety of their employees while also having only beneficial impacts on production and plant efficiency.
A decade ago, this expectation would have been absolutely unreasonable, but today it's status quo.
Below is one real scenario (names changed) that might sound familiar to many who work in the safety field.
One Saturday morning, Jason got a call from the HR department representing the company where he'd interviewed the prior week. "Hello, Mr. Smith, we are pleased to inform you that we would like to extend an offer to you for the new position as safety manager." Jason gladly accepted and looked forward to applying all of what he learned in school and his last position as safety manager with a smaller company. He was to start on Monday and couldn't be more excited to really make a difference. The new company was quickly growing, with three existing locations and two more being built. It had more than 700 employees and was replacing the outgoing safety manager with hopes of finding someone more suited to the company’s need to stay compliant and safe while minimizing impact on production and growth.
Forty-eight hours later, Jason sat down in his own office that was just down the hall from that of the plant manager. He had a window looking out onto the heavily automated production floor, and he saw several workers gathering around one of the machines at the end of the production line. He had a meeting in 20 minutes but figured it wouldn't hurt to get out there and learn how they were using their safety systems currently. He put on his safety vest, hard hat, and safety glasses and double checked to ensure he'd worn his steel-toe shoes that day. With a deep breath, he took his first visit to the production floor as the new safety manager and stepped right up to the machine that was being serviced by three employees. What he saw next helped make his decision of what to focus on first an easy one.
The guarding was opened, and the equipment wasn't running. The equipment was more like four pieces of equipment working together as a case packer. With an automated robot, two powered conveyors, and a pallet stacker, this piece of equipment had been installed to replace three line operators, but at the present time it seemed to be failing to pay off. Jason could see the frustration on the faces of the workers, but he felt compelled to introduce himself and learn more about what they were doing and how they were being safe.
"Hi, Jason Smith, your new safety manager," he said while extending his hand to the worker who looked to be in charge.
"Paul Lundy, good to meet you. Anything we can help you with?" As Paul shook hands, he took a look back at the equipment as if to do a last-minute check for safety compliance.
"Yes, actually I was just coming out to do a quick tour but couldn't help but notice that you three are servicing this equipment, but I don't see any locks on the main disconnect here. Is there something I'm missing?"
Paul smiled. "No, you're not missing anything," he said. "In fact, I thought you were going to say something when you came out here. We actually lock it out in the MCC [motor control center] room because that's how we've always been taught to do it." Jason looked around and noticed the main pneumatic wasn't locked out, and neither was a secondary electric that powered the pallet stacker. Before leaving, he instructed them to lock out both of those sources and ensured they were aware of the non-lockable counterbalance weight in the robot in case that posed a hazard during the service.
Jason walked slowly back to his office and immediately searched for their lockout/tagout program. He found a dusty binder on the shelf labeled "Lockout/Tagout Procedure" and opened it to investigate. Just as he'd thought, this was a bigger problem than they probably knew: no machine-specific procedures.
After more digging, Jason found that the following components existed:
- Corporate policy with a general lockout/tagout procedure inside
- A DVD that was used for training all authorized employees
- A list of authorized employees and the dates when they were last trained
Knowing that the workers were currently working on equipment in a way that was not only unsafe, but also could result in huge OSHA fines, he decided this was his best first move as the new safety manager. During the next two weeks, a new corporate policy was created and everyone was given a refresher training to ensure they knew the plan that was being rolled out and how to work safely in the meantime. The plant manager was in full support of this update and didn’t look too surprised when Jason requested that they bring in outside help rather than attempt to create it in house, due to the urgency and importance. After doing his research, Jason found a company that specialized in comprehensive lockout/tagout compliance. This was exactly what he needed.
Eight weeks later, they had a new, comprehensive lockout/tagout program in place that had not only everything needed to ensure employee safety and OSHA compliance, but also they had a solution that helped them run more efficiently. With iPad minis in waterproof cases, the workers could now access the graphical lockout/tagout procedure for their equipment simply by scanning a QR code. They could prove they had locked it out with time stamps and show management how safe and efficient they were being simply by using the iPad. Everything was going as planned, and Jason could not have been more pleased with the results.
The plant manager, Karen, called Jason in for his 90-day review and began by closing the door. Not good, Jason thought, none of our other meetings had the door closed. He had been doing his best to seek out the top priorities in the facility and apply their resources sparingly to get the jobs done. He knew this lockout/tagout program was a big investment, but since the plant manager signed off, he assumed she agreed. As the doubt raced through his head with various scenarios, Karen looked at him and smiled. "You've made quite a splash here for your first 90 days, I hope you can maintain this pace," she said. "I called you in a week early for your 90-day review because this couldn't wait. I had my COO run the numbers and, as we suspected, the lockout/tagout program we just invested in has impacted our numbers in a big way. When we started this project, we simply hoped that it didn't have a negative impact on our bottom line. What we found was something we didn't expect at all: Our line efficiency averages are up across the board. While we thought the investment in the solution was steep at first, we are on track to recover all investment costs in the next 45 days. This is exactly the kind of thinking we need here, and I'm promoting you to director of safety overseeing our five facilities across the U.S."
Jason couldn't believe what he was hearing. He simply sat there with a stone-cold poker face and replied, "Thank you, I appreciate the offer. When will you need me to start?" Not surprisingly, he heard back, "Today."
The Value of a Modern Approach
In this scenario, the safety manager was brought into a new environment with which he was unfamiliar and right away recognized two things with the existing lockout/tagout program: lack of the basic safety requirements, as well as a lockout/tagout process that was highly inefficient. For many in this situation, it might be tempting simply to go for the quick "Band-Aid" fix and address only what was identified as a safety/compliance issue. In this case, the manager looked ahead and saw this as an opportunity to bring together safety and production with a solution that accomplished what everyone was looking for.
After doing his research, he saw this as an opportunity to take an inefficient safety program and upgrade it with a new, modern approach that accomplished what would have been impossible only a decade ago. He simultaneously improved their safety in a dramatic way while also contributing directly to overall plant efficiency and productivity in a way that was easily measurable and proven.
A retired OSHA inspector with more than 30 years of experience issuing citations was quoted as saying, "One of the biggest problems I see today with lockout/tagout is the ignorance that if it's done right, it adds to efficiency."
For any safety manager who wants to see whether his or her company might benefit from a refresh of the existing program, a good first step is to seek out professional assistance to learn more. Whether it's reaching out to a professional safety group or simply starting with a Google search ("What does a modern lockout/tagout program look like?"), the path toward upgrading will be rewarding from day one.
This article originally appeared in the March 2014 issue of Occupational Health & Safety.