Advanced Lockouts: Reengineering Safety Programs for Efficiency
Companies can adapt quickly to engineer in efficiency and safety.
In the not-too-distant future, U.S. manufacturing companies will evolve into a different way of using lockout/tagout.
When asked, most safety managers will tell you that lockout/tagout saves lives. When you ask the same question to a production supervisor, plant manager, or many CEOs, you can expect a response more in line with: "Lockout/tagout is something we have to comply with, but there are times when you just can't lock it out to perform the job. Also, lockout/tagout isn't the only safe way to service equipment, so it feels like we're artificially slowing down every time we lock it out."
Both safety and production are correct. Yes, lockout/tagout saves lives, but it is not the only tool permitted for use thanks to modern technology and an evolving perspective of how to enforce workplace compliance by OSHA.
What is OSHA looking for?
Quite simply, that you comply with federal minimum standards (or a respective state OSHA standard where applicable) and follow the rules to protect workers from unexpected restart when they are servicing equipment.
What is lockout/tagout at its core?
Using a lock and a tag on an energy isolation device (such as a valve or an electrical switch) to provide an effective physical deterrent to inadvertent reenergization. Lockout/tagout procedures are designed to isolate, dissipate, and block all energy from entering the system during the service work. It's very effective, however, it's not always the best tool to use for every type of service.
So what gives? How can a company use something else?
Best answer: very, very carefully. If you're ever using an alternative means of protection, the onus is on you to prove not only to OSHA (when you're facing a fine) but to a jury when you're in court if there's an accident related to servicing equipment and the company-approved "alternatives' did not work (i.e., a guard failed).
Seems risky, why doesn’t a company just lock it out every time?
Because some types of service require the machine to be partially live to do the servicing work. Besides when employees need to have partially live equipment, lockout/tagout might be the best tool for the job when performing major maintenance. But for minor maintenance, there can be a lot of excessive downtime associated with lockout that might be able to be engineered out with good alternative solutions, such as machine guarding, custom procedures, and training.
Example of the need for alternative measures (that are as effective as lockout):
An authorized employee, a line mechanic with more than 25 years' experience, has seen this problem before, but this time it was more difficult to identify the root cause and fix.
Just then, a passer-by asks him what he's doing servicing the filling machine without locking it out. They argue about whether the machine should be locked out or if what Steven is doing is okay. The next day, he's called into the HR office and is told that he is terminated, effectively immediately, for failing to lock out the machine when he was servicing it.
Steven tries to explain that he had to do diagnostic work and there would be no way to complete that work if he performed the full lockout of the equipment. The HR director said, "I'm sorry, this is a zero tolerance policy and you know the rules. These rules exist for your safety and the safety of others."
Steven retorted "You may not know this, but this company expects me to do what I do in order to keep this business afloat." The HR manager dismisses his comment and they complete the termination paperwork.
Just a few short years later, the company is filing for bankruptcy. The cause: rising manufacturing costs in the United States. The company stated that due to tight U.S. regulatory restrictions, the business must close its doors after more than 100 years in business. Looking deeper into where things took a turn for the worse reveals that the overall line efficiency was in decline ever since Steven's firing.
Unfortunately, this story is all too common in the United States. Many companies have safety policies that unnecessarily restrict the servicing of equipment while partially energized or even fully running. Due to misunderstandings of the federal regulation for the control of hazardous energy, many safety policies are built around the premise that under no circumstances can you service a piece of equipment while live.
And this is just not true. Furthermore, having a rigid stance on lockout/tagout exclusive usage for all servicing tasks is costing companies untold amounts in lost productivity and actually can create a less-safe servicing scenario than if a well-engineered effective alternative is used.
The Solution: Engineering Out Lockout/Tagout
OSHA wrote in an exception to the lockout/tagout clause in 1910.147(a)(2)(ii)(B): An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle. Note: Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).
However, before you run out there and stop using lockout, you should know that since they released this regulation in 1989, OSHA has cited hundreds of companies for using this exception. It's not that you can't use the exception, it's that you can't use the exception to increase the risk exposure to the employee. So if you are going to have an alternative procedure be used from lockout/tagout, you had better be sure it's effectively equivalent to lockout/tagout or you'll be cited for failing to comply with lockout/tagout.
Here's another way of saying it: OSHA requires that you have a lockout/tagout procedure to provide protection during any type of service from lubrication and unjamming all the way up to installation and removal of the equipment. It's like having one tool in your tool bag: a hammer. And lockout/tagout does just that to production. While it's proven to be effective and safe, it's not necessarily the right tool for the job.
While OSHA does not require additional procedures to help make productivity improvements, they are not saying you can’t, either. OSHA's stance is that as long as it's proven to be as effective as lockout/tagout for the particular service, then it's permitted.
So what does it mean to be "as effective as lockout/tagout"? Good question and nobody really knows because there's no way to prove you're right, only a way to prove you're wrong (when there's an accident).
Industry best practices are evolving quickly, and companies are realizing that lockout/tagout is not a production killer unless you let it be. By taking another look at the overall lockout/tagout safety program, companies can oftentimes reengineer their safety program to incorporate in exactly what you would think makes sense: Alternative Protection Measure procedures (APM). These procedures serve as the means of which to control the machine in a safe state in order to safely perform a prescribed service.
Strive for Perfection, Settle for Success
To successfully implement an Alternative Protection Measure program, a company must plan accordingly to list the machines it wants to engineer in alternatives for. Then, whatever procedure the company develops must have limitations to what servicing activities can occur and what areas of the machine this covers. Lastly and most importantly, a properly engineered safety program must include means to verify that the procedure was effective—every time.
So why take the risk to develop APM procedures?
Because your people are likely already doing it and it's not being documented. If someone gets hurt, your company will be in very hot water by allowing it to occur.
Summary
Remember one golden rule when engineering out lockout/tagout: No additional risk can be introduced to the employees by using alternative procedures. If you can design alternative procedures and an overall alternative program to ensure equivalent protection for specific tasks . . . the sky is the limit to enhancing productivity.
This article originally appeared in the August 2015 issue of Occupational Health & Safety.