Beyond Padlocks - Developing Lockout Systems that Save Lives, Time, and Money.

LO/TO (m) You've got all the right tools: safety padlocks and lockout tags; circuit breaker, electrical, and valve lockout devices; even wall-mounted departmental lockout stations. So you're ready for your OSHA Lockout/Tagout inspection, right? And your employees have everything they need to safely lockout their equipment, don't they?

Not necessarily.

While the right tools and equipment are a vital part of a successful, OSHA-compliant LO/TO program, not one of the five most frequently OSHA-cited sections of the LO/TO standard is focused on protective materials and hardware (i.e. the lockout padlocks and devices.)

The five sections of the LO/TO standard most often cited by OSHA are:

Failure to develop, document, and utilize effective LO/TO procedures
Failure to establish and implement a written program
Failure to conduct a periodic inspection of all energy control procedures
Failure to provide employee training as described by OSHA
Failure to clearly outline the scope and rules of your LO/TO program,
and the means to enforce compliance with procedures

This list reveals that in terms of OSHA compliance, LO/TO regulations are focused on having a sound program and machine-specific procedures in place, along with comprehensive training and effective ongoing communications with your employees.

However, the advantage of effective Lockout/Tagout procedures goes well beyond OSHA compliance. Yes, LO/TO is a major OSHA-inspection focus - in fact, it's the most cited violation for general industry. But rather than focus simply on avoiding citations for non-compliance, take a look at what a comprehensive, effective LO/TO program can accomplish for your company:

Save Lives - Effective LO/TO procedures can prevent an estimated 250,000 incidents, 50,000 injuries and 120 fatalities annually.
Cut Costs - Avoiding accidents also avoids lost employee time, insurance costs, and legal fees.
Improve Productivity - Properly followed LO/TO procedures speed equipment maintenance, minimizing downtime. This is why Lockout programs are widely considered a Best Practice for industry.

THE FOUR-STEP PLAN TO AN EFFECTIVE LOCKOUT/TAGOUT PROGRAM

To gain the advantages mentioned above, you need to be in compliance with both the letter and the spirit of the OSHA law. This isn't as difficult as you might imagine. Follow this four-step plan to create your own energy control program. Once completed, your organization will be in a better position to gain productivity benefits while ensuring the safety of your employees.

STEP 1: Develop and document your energy control program and written procedures

LOTO Procedures The OSHA standard requires that "...the employer is to establish an energy control policy/program consisting of energy control procedures, employee training and periodic inspections..." and that "procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in locking out equipment." To meet the standard, each piece of equipment or similar equipment must have its own LO/TO procedure.

The written lockout policy establishes the "nuts and bolts" of your overall lockout program. Begin by reviewing and documenting your current lockout/tagout program, then build on this with machine-specific procedure development, employee training, and periodic inspections.

OSHA has a Lockout/Tagout Tutorial on its web site (www.osha.gov) that provides additional advice. Software programs are also available that can take you through the entire process step-by-step, starting with a sample energy control policy. These programs offer a guide to creating an effective lockout/tagout policy. For the most benefit, choose a program that allows you to create, output, and update easy-to-follow, visual, machine-specific procedures for all of your equipment.

STEP 2: Identify and mark all energy control points

To be compliant with OSHA and ANSI standards, all energy isolating devices must be clearly marked to show both the energy magnitude and purpose of that device. For example, authorized workers need to know the voltage and purpose of an electrical energy control point so that they can confidently follow the correct procedures when locking out the affected equipment.

Locate and mark all energy control points, including valves, switches, breakers and plugs, with permanently placed labels or tags. Cross reference each label and tag with the corresponding step # in the posted energy control procedure for that equipment. Include information about the magnitude and purpose of the control point as stipulated by OSHA for electrical disconnects and as recommended by ANSI for all isolating devices. Industrial-duty labels and tags are available that clearly identify various energy sources being disconnected. Alternatively, some companies choose to invest in portable industrial label makers so they can produce custom energy control labels as needed.

STEP 3: Equip your employees with the proper lockout tools and warning devices

To be OSHA compliant, employers must provide lockout devices that are "standardized by size, shape or color, be distinguishable from locks used for other purposes, identify the individual who applied the lock, be durable, be strong enough to prevent removal except by using excessive force and remain under the exclusive control of the individual who attached them." Tagout devices must warn against hazardous conditions and must include a legend such as "Do Not Start - Do Not Operate."

Ultimately, it's the proper and religious application of the lockout hardware per the established procedures that makes for a successful lockout program. To this end, it's very important to know and document specifically what devices are acceptable for use at each and every lockout point. There is a tremendous range of sizes and shapes of valve operating handles, circuit breaker switches and various other energy control means. Reputable providers of lockout devices will have developed product series that properly fit the majority of these, and several offer reference guides and other fit information. Some products are more versatile than others, fitting a broader range of the spectrum.

STEP 4: Train your employees, communicate and conduct periodic inspections

Obviously, even the most comprehensive lockout/tagout program will be useless if it isn't followed consistently. That's why the OSHA standard requires employers to provide training, as well as conduct periodic inspections (at least annually) to ensure that the procedures are being followed.

A lack of training can have tragic results. In August 2007, OSHA conducted an investigation following the death of a fleet mechanic who was pinned between two trucks while performing maintenance on a vehicle at the company's worksite. OSHA issued one willful violation for alleged failure to implement and train employees on a lockout/tagout program to be used when performing vehicle maintenance.

"This was a preventable tragedy," said the director of OSHA's area office.

OSHA provides advice on how to train, and verify that your training is up-to-date. First, establish formal training programs for each of the three categories of employees for lockout: 'Authorized,' 'Affected,' and 'Other' employees. Companies can enhance or create a training program by using some of the training DVDs, handbooks, and posters that are currently available. There is also software available that provides training modules and quizzes to help formalize and document effective training procedures.

Effective Lockout/Tagout programs are not just about having the right padlocks or avoiding OSHA fines. Establishing and maintaining a comprehensive Lockout/Tagout program that is understood and embraced by your employees will cut costs, improve productivity and, above all, potentially avert an accident or potentially devastating employee injury.

For more information about complete lockout/tagout solutions, including lockout devices and tags, lockout stations, and graphical procedure writing software, visit www.bradycanada.com/lockouttagout or call 1-888-272-3946.

This article has been published with permission from Facility & Safety Management - www.fsmmag.com