When it comes to taking the important first step in setting up your energy control procedures (OSHA’s lockout/tagout standard 1910.146), the sky is the limit. Lockout/tagout (LOTO) is a key safety program when working with any power source including electricity, hydraulic pressure, pneumatic pressure, water pressure, thermal energy and even pyrophoric chemicals that combust upon contact with the air.
As companies dive deep into the world of LOTO, their approach is usually comprehensive. What separates the rare few greats from the rest of the overworked industry is how the program proceeds from that point forward.
As facilities are upgraded, are LOTO procedures updated to reflect these changes?
- Are specific isolation valves and electrical disconnects put in place for each new production line?
- Are annual evaluations being conducted? The answer to that last question is frequently: No. Not many companies follow up on their annual evaluations, and only a fraction bring in a fresh set of qualified eyes to ensure the process is optimally completed. Why? Because the annual evaluation process tends to become yet another task for overworked safety professionals.
Enterprise growth can also become the root of many challenges, particularly if safety programs are not properly scaled. Growth outpacing safety programs is one of the main reasons the 1910.147 control of hazardous energy (lockout/tagout) is on the top 10 list of OSHA’s most cited standards year after year.
In the most recent year reported, fiscal year 2020, OSHA assessed a proposed $7.5 million dollars in penalties for violating the LOTO standard, making it the sixth most frequently cited agency standard. Food manufacturing, fabricated metal products, plastics and rubber products, wood products and primary metal manufacturing are the most heavily penalized industries.
More recently, in September 2021, OSHA proposed $1.67 million in fines for an Ohio aluminum parts manufacturer following an investigation into the death of a 43-year-old worker struck by a machine’s barrier door in March 2021. OSHA alleges the company allowed employees to bypass guarding mechanisms designed to protect them from the barrier door closing on them, and that a malfunction in the door's optic control existed prior to the deadly incident. The worker was loading a part into the machine when the barrier door closed, fatally injuring him.
“A worker lost his life because the company put the value of production speed before the safety of their employees. OSHA will continue to hold bad actors accountable and emphasize the importance of complying with safety and health requirements that can save lives,” said acting OSHA chief Jim Frederick in a press release found on OSHA’s online Newsroom.
Common LOTO Procedures Oversights
LOTO gap assessments are conducted to ensure the procedures in place can indeed protect employees from injury and equipment from damage. Whether the assessment is conducted in-house, or outsourced to a third party, some of the most commonly found issues include:
- Incomplete documentation of required training.
- Failure to update procedures that reflect changes in operations and equipment. Example: Was a production line relocated to make way for a new process? Were procedures and training materials updated to reflect this change?
- Not paying attention to equipment stored energy. This is a common oversight identified during our gap analyses. If the only isolation valve for a piece of process equipment running 150 psi is in the ceiling, there is a high likelihood of stored pneumatic energy waiting to be released.
Effective Energy Control Procedures
OSHA estimates that LOTO standards compliance prevents 120 fatalities and 50,000 injuries each year. These numbers clearly illustrate the tangible effect proper LOTO procedures can have on employee safety, regulatory fines violations avoidance and uptime.
What are key components to set up proper energy control procedures?
- Identify the energy types employed within a piece of equipment. Is it electrical energy only? Is the equipment piece in question operating with a large press brake with a stored energy component with gravity?
- Identify how to isolate the energies that are external to the equipment.
- Identify what stored energy remains after shutdown and how to release that stored energy.
- Identify the way in which energy is controlled. Are these controls compliant and effective?
- Evaluate current procedures and ask yourself: If these steps are followed, would I be safe putting my hand in potentially hazardous areas, or taking off guarding
- Ensure there is clear communication of proper LOTO procedures for each piece of equipment.
Helpful Reminders: The Do’s and Don’ts
It all starts with shared ownership. Documenting and making standards easily accessible to employees is a starting point, not the endgame. A true commitment to safety and compliance will require training, reinforcement of protocols and open channels of communication.
Approach equipment with fresh eyes. Even if a piece of equipment has been at your facility for decades, when it comes to safety, it needs to be looked at as if it had just been added to your line.
Ask questions. What energy sources does the equipment require? How does it operate? What does it do? What is the required maintenance and is there a plan in place for it? Where is the power shut off? Are training manuals and OEM materials easily accessible?
Craft easy to understand procedures. When documenting LOTO safety procedures, it is important to keep in mind the levels of experience and seniority of the employees coming in contact with a piece of equipment. The content needs to be easily digestible and always within reach. Remember that these materials need to answer key questions like how to recognize when a piece of equipment is at a zero-energy state and how to isolate a specific type of energy.
Label control points. A clear labeling system will be easily identifiable by your employees, and of course, it will need to correlate to documented procedures. This step is crucial to eliminate potential errors. Approach this step from the perspective of a brand-new tech working on a piece of equipment. The importance of looking at safety measures with fresh eyes cannot be overstated.
Don’t stop with simple digital training content. While computer-based training programs, videos and other digital assets are powerful tools; best-in-class safety programs rely on robust content, assessments and field applications. Reinforcement is key to success.
QR code technology is your friend. Labeling software has improved how control of hazardous energy in a facility is documented, labeled and audited. QR codes ensure that labels placed at each energy isolation point (EIP) are unique, this helps eliminate mistakes during maintenance and servicing. Scanning QR codes with mobile devices and tablets provides employees easy access to view, complete and audit LOTO procedures.
Standardization and visibility across multiple sites can be attained with the right technology. Safety procedures at the asset level are key to keep employees safe and protect equipment. However, a comprehensive view of a facility or multiple facilities can also be attained by employing asset management and visualization software. Asset management software can provide visibility into multiple locations via desktop/laptop with dashboards showing activities, dates, renewals, anniversaries and training for multiple-energy source equipment. These safety activities can be tied to existing computerized maintenance management systems (CMMS).
Don’t forget about automation. As equipment in every industry continues to move toward automation, it is critical that assessments of new risks and safety procedures be performed. Furthermore, as equipment evolves so do the requirements to energize these assets, which in turn means LOTO procedures must be revised.
OSHA Looks to Plan a Revised Standard
Speaking of revisions, OSHA concedes it is not keeping up with LOTO technological advancements. The agency has stated “computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with OSHA's existing lockout/tagout standard. The use of these computer-based controls has become more prevalent as equipment manufactures modernize their designs.”
OSHA’s 1989 LOTO standard has not kept pace with the national consensus standard ANSI/ASSP Z244.1, which is updated every five years to keep it relevant as technology and the nature of work changes. In the most recent regulatory agenda, OSHA proposed to update its 30+ year old standard in January 2022.
Our Advice: Be proactive
The world of LOTO is changing. Traditional control measures such as physical locks and tags are being challenged by computer-based controls as the workplace environment becomes more automated and digital. Most industrial environments rely on multiple energy types ranging from electrical, thermal and gas to radiation, vacuum, explosive and propellants; each source calls for a tailored safety approach. Knowing that a revised OSHA standard is in the works, our advice is: be proactive.
Use internal experts from different departments or a “fresh pair of eyes” from a third-party service to assess if gaps exist between your written procedures and program and your sources of energy, control procedures, labeling, data collection and training. Remember that there are tools and software available to help you update and build a best-in-class LOTO program to protect your people and equipment.