Not every idea will work in every situation, but that should not deter you from engaging your shop floor experts to incorporate new tactics. (UL EHS Sustainability photo)

Lockout/Tagout: Making Sure Your Organization is All In

When it comes to LOTO, a worker may not expend the effort to get critical information or supplies if he has to go more than 20 steps or wait more than 10 seconds. This is especially true when there is intrinsic motivation to "help" the team.

As technology evolves and the industrial landscape grows more complex, companies must remain focused on the basics. Three million American employees regularly service machinery and equipment, facing the risk of becoming victims of improperly controlled hazardous energy. When these workers are injured, their recovery takes an average of 24 days, according to OSHA.1 Even worse, failure to control hazardous energy is too often a deadly error.

To combat this, OSHA's lockout/tagout (LOTO) standard regulates the necessary procedures for disabling equipment and machinery by holding employers responsible for protecting employees from hazardous energy sources—electrical, hydraulic, mechanical, chemical, thermal, and pneumatic.

LOTO significantly improves the safety environments of the craft workers, machine operators, and laborers who are most likely to be injured by hazardous energy. In fact, it prevents about 120 fatalities and about 50,000 injuries each year. To protect employees and remain compliant, companies need to ensure their employees have convenient, on-demand access to LOTO protocols.

The Problem
Imagine the following scenario.

"Bob, here's the work order to bring the main hydraulic unit online down in the pit. Be sure to follow the valve sequence on the LOTO sheet in order to prevent it from damaging the newly installed seals," said Gary, a floor manager at a chemical processing facility.

As Gary walked away, Bob threw the work packet in the tool box and thought to himself, "I have been working here 19 years and know how to bring the hydraulic unit online."

John, a new hire, overheard the conversation on his way to the hydraulic pit. Once there, he surveyed the series of valves and pipes and thought, "I've seen Bob just turn these four valve handles and it came right up." John knew that the work packet had the sequence, but he didn't want to go get it. He did, however, want to help get the hydraulic unit online as soon as possible, so he decided to bring the unit up on his own without checking the work packet.

Addressing LOTO Violations
How often has the above scenario happened in your organization? It's probably happened more than once, if your company is like most. LOTO is consistently listed in OSHA's Top 10 most commonly cited violations. What if the newly installed seals mean Bob’s traditional approach no longer works? What if John misremembers the sequence and causes a seal failure, damage, or, worse, an injury?

When it comes to LOTO, a worker may not expend the effort to get critical information or supplies if he has to go more than 20 steps or wait more than 10 seconds. This is especially true when there is intrinsic motivation to "help" the team. With this in mind, ensuring workers take the necessary actions may seem impossible. However, with the right strategy, you can greatly decrease employees' likelihood of failure.

Proper LOTO enforcement begins with a solid foundation of training. The onboarding process for new employees should stress the importance of compliance with federal, state, and company policies. This should not be presented in a way that allows employees to skim a couple of documents and then sign to acknowledge their agreement. Rather, present training information in an interactive format, then quiz employees on what they've learned.

Training does not stop once a new hire has settled down at your company, though. All workers, including management, need regular refresher courses to stay as safe as possible on the job. Further, when new policies or practices are implemented, make every single employee aware of the changes. An active employee education program could be the reason your company avoids fines and other regulatory action, prevents workplace injuries, and ensures no lives are lost due to improperly controlled energy from machines and equipment.

Good training is crucial to ensuring proper procedures, but it's not always enough. You need to make it easy for your employees to comply. To do so, why not leverage the technology that is already in your employees' hands?

Employers can easily create QR codes that reference the procedure instantly on smartphones. This way, workers don't have to go back to the shop and get paper copies. Alternatively, share a hyperlink to an in-house YouTube account that models the appropriate steps.

If you don’t have Wi-Fi or internet connectivity in your facility, text a photo of the LOTO sequence to a smart device as part of your pre-job planning. The technology to which your workers have access is ever-evolving and usually just a click away. Many younger workers already have a firm grasp on this technology and can leverage it in a way that works for them. This approach can help enhance their on-the-job experience while engaging them throughout the process. An engaged employee is a safe and happy employee.

Beyond improving individual employee safety, having instant access to LOTO procedures will facilitate your organization’s audits and oversight. Feedback will not only ensure LOTO compliance audits are completed, but also will identify gaps or "work arounds" that need to be corrected. Manually writing down a procedure step by step can be cumbersome; by involving technology, a worker can make note of a required change immediately at the machine center instead of memorizing it and documenting it later.

Of course, while your organization may benefit from employing all of these methods, you have to find a mix that works best for your employees and culture. LOTO protocols should not be a static part of your floor management program. Instead, regularly take a step back and decide whether the systems you have in place are allowing your floor to run as safely and smoothly as possible.

Not every idea will work in every situation, but that should not deter you from engaging your shop floor experts to incorporate new tactics. LOTO is essential to saving lives, preventing serious injuries, and avoiding heavy fines and censure by regulators, so your organization needs to take the necessary steps to make it work.

References
1. https://www.osha.gov/SLTC/controlhazardousenergy/

This article originally appeared in the March 2017 issue of Occupational Health & Safety.

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