Building a Culture of Safety Around an Effective Lockout/Tagout Program

Building a Culture of Safety Around an Effective LockoutTagout Program

Developing a lockout/tagout program is easier said than done.

In order to establish the safest possible working environment, it is essential to first build a company culture that promotes and values electrical safety, both in words and actions.

This isn’t always easy. Resistance to change is often one of the biggest challenges for EHS professionals. Managers responsible for safety programs must overcome this resistance when implementing new policies. There are actions that can be taken to help minimize any apprehension towards cultural and operational changes. The steps below outline the stages of culture change, how to implement them most effectively, and how to translate these changes from philosophy to practice by developing an effective lockout/ tagout program.

Three Stages of Culture Change

Leadership buy-in. Without buy-in or engagement from company leadership, any initiative will fail. Leaders must demonstrate through example and be able to back up words with actions. Leaders should focus on minimizing any negative consequences, whether actual or perceived, of implementing new safety protocols. Any stigma of blame that may come with reporting safety risks or hazards needs to be eliminated so that employees can be open and honest when talking with management. As a program is being implemented, employees need both encouragement and proof that the new expectations are permanent until further notice. Signage, official announcements, and updates can help, as can incentives to reward compliance. Keep education and information within reach; if employees feel more prepared, then they will be more likely to keep progressing.

Educate staff about why changes are necessary. In facilities where there have been recent incidents, this may not be difficult. Plants that haven’t had recent incidents will relate better to an emphasis on active prevention and education about why periodic safety program updates are needed. Operator error is one source of risk, especially with novice personnel who have received insufficient training and are working on unfamiliar equipment or insufficient maintenance. Even the most competent personnel are at risk for complacency and mechanical or system failures due to insufficient maintenance.

Focus on training and consistency. Throughout the process, it is useful to try different approaches to behavior changes that are needed at each stage. For example, if the company culture is to avoid addressing a problem, it may be too early to push change. In this case, the focus should be on education instead.

Further, this isn’t something to set and forget. To maintain positive change, once the program has been established, the focus needs to switch to providing personnel with ways to keep up with compliance, including preparing them for situations where they are most likely to slip back into unsafe behaviors.

Figuring out where to start upgrading your entire electrical safety program can seem overwhelming. It’s okay to start small, and reevaluating your lockout/tagout (LOTO) program is a good place to start.

Developing a Lockout/Tagout Program

LOTO prevents the accidental start-up or release of stored energy during set-up, maintenance, and servicing of equipment by preventing access to the energy source. Effective implementation prevents an estimated 120 fatalities and 50,000 injuries each year. In contrast, 10 percent of all serious workplace injuries can be attributed to the absence or ineffectiveness of lockout/tagout procedures. It’s clear that proper LOTO policies improve the effectiveness and outcomes of workplace safety programs.

There are five essential elements of an effective LOTO program:

Policy. Program documentation sets your company’s overall LOTO policy and expectations. It should outline the program’s purpose and scope, company safety rules, specific lockout and/or tagout procedures and necessary training requirements, as well as how compliance will be enforced.

That said, the policy is only effective if it’s accessible. It needs to be written clearly enough that all employees can understand it. The policy is a living document that needs to be able to adjust with changing conditions and regulations.

The key to developing policies and procedures that are effective, understandable, and comprehensive is to collaborate across departments. Including the perspectives of safety mangers, maintenance personnel, operations staff, electrical and engineering departments, and human resources will prevent complications down the line by catching blind spots and roadblocks, and facilitating buy-in.

Procedures. A LOTO program should include written procedures specific to each piece of equipment or type of equipment. Even simple, single energy source equipment can pose a hazard, so it’s important to develop instructions for both simple processes and complex situations such as multiple energy sources and/or multiple crews and locations.

As for what to include, instructions should cover where and how to de-energize the energy load; how to release hazardous stored energy (discharging capacitors, for example); and how to verify that the equipment is de-energized and cannot restart while in the locked-out condition. An outline of these steps would generally include:

  • Providing verbal notification of intentions to all affected employees, adding signage and barricading the area where appropriate.
  • Shutting down a machine and/or equipment using standard stopping instructions.
  • Referring to pictures and steps to isolate all energy sources.
  • Securing each energy source with a lockout device. If equipment design does not provide accessibility for a lockout device, then additional preventative measures (such as removing a fuse) should be used in addition to tagout warnings.
  • Releasing all residual and stored energy.
  • Verifying that all energy sources have been de-energized.
  • Notifying all affected personnel that normal operations can resume.

Training. NFPA 70E requires three types of employees to be trained for an effective LOTO program, authorized, affected and other employees.

Authorized employees are those responsible for locking and tagging out equipment. These employees must be able to demonstrate competence in executing the specific LOTO procedures they will be using. Their training should also identify all the hazardous energy sources present in the facility as well as the methods used for isolating and controlling them.

Affected employees are not directly responsible for LOTO procedures, though they do interact with the affected equipment and must understand the general process (definitions, responsibilities, devices) and why it is important to avoid starting up or using equipment during these procedures.

Any other employees who work in an area where energy control procedures will be utilized (such as office or warehouse personnel) also need to be aware of the importance of the LOTO program.

Devices. Devices are only effective as part of a company’s overall approach to training, procedures, and review. The devices used for lockout should be robust, unique, and easily identifiable. When in use, a warning tag that also identifies who installed the device should also be securely attached. LOTO devices should be able to be installed without tools, and the keys for locks must remain with the individual(s) who installed the devices to ensure that the power source cannot be re-activated by anyone else.

Review. The final element of inspection and review ensures a lockout program’s effectiveness. Annual program documentation and procedure review is needed due to employee turnover, and to ensure that a process doesn’t become too comfortable and prone to error.

Another important element of review is continually assessing your safety program against industry best practices regarding the most current technology available. Understanding where safety tools used in your program fall within the Hierarchy of Risk Controls is one way of measuring program effectiveness.

The hierarchy ranks risk control measures from most to least effective:

  • Elimination physically removes the hazard.
  • Substitution replaces the hazard with something non-hazardous or minimizes the hazard. *Engineering controls prevent access or act as a barrier between personnel and hazards. 
  • Administrative controls attempt to change the way people work through training, procedure, policy, and signage.
  • Personal protective equipment can be effective in tandem with administrative controls but does not eliminate the hazard.

Elimination and substitution remove or reduce the hazard itself; the lower three tiers only reduce exposure to the risk. These lower tiers of the hierarchy may often be easier to implement but are not necessarily the most cost-effective for the long-term.

LOTO is still mainly a manual process that depends largely on administrative controls (procedures and training) for the proper implementation of tools and devices that fall within any other level. The effectiveness of administrative controls depends on the mitigation potential of the controls and how consistently they are followed.

As a manual process, there is a lot of room for potential error. Human factors, such as being rushed, losing concentration, using shortcuts, or fatigue are a few sources of potential errors that can lead to injuries or worse. Effective lockout programs account for human factors by including other layers of safety protocols to provide additional protection and risk mitigation.

Ideally, your safety program should continually be evaluated for ways to complement existing electrical safety control procedures or replace less-effective ones with safety technology that’s higher up on the hierarchy of risk controls. Two examples safety changes are the following: adding real-time status updates and verification to allow the safety manager to monitor the lockout/tagout process, or the ability to scan equipment barcodes and immediately access the correct LOTO procedure through a mobile device.

Conclusion

In a perfect world, businesses could protect workers by eliminating all workplace hazards. In the real world, the best options are often to mitigate dangers by prioritizing electrical safety across company culture, operational procedures, and product selection.

Applying the hierarchy of risk controls to electrical safety planning, developing the right LOTO procedures, and providing the proper education are great ways to start. Implementing these changes improves the working environment and minimizes long-term costs related to electrical incidents. Even more importantly, though, these changes can save a life.

This article originally appeared in the November/December 2019 issue of Occupational Health & Safety.

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