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Of the numerous standards that repeatedly earn a spot on OSHA’s annual Top 10 Most Frequently Cited Violations list, none surprises me more year after year as the control of hazardous energy, more commonly known as lockout/tagout (or “LOTO”). It’s not that I am unfamiliar with LOTO’s reputation as a hassle in the workplace; the excuses I have heard for avoiding locking equipment out are diverse:
- “Couldn’t find a lockout device that fit.”
- “I told my supervisor what I was doing. He knew not to power up.”
- “I needed to be able to move the machine to complete the repair.”
- “He had it locked out. Why did I need to put another lock on it?”
- “Not sure where all the lockout points are.”
- “Too much downtime, dude.”
- “Wasn’t trained how on that piece of machinery.”
- “There was no power to that area. Didn’t think about pneumatic stuff.”
- “This machine room is empty. No one comes in here.”
- “I had the machine down for three minutes. What’s the point?”
What is somehow lost among these all too common excuses is the fact that LOTO, when done correctly, saves companies money. Why then is it treated like a waste of time?
The Impact of Failing to Lockout
Consider the consequences of an injury that occurs as a result of a failure to lockout/tagout.
First, operating costs immediately increase. The expenses might come directly from adjustments to workers comp rates or come from regulatory fines levied by outside agencies. Other costs come indirectly via lower productivity; injuries and accidents devastate employee morale, impacting both pace and quality of work. Suddenly, a machine that was instrumental to the manufacturing process is untrustworthy. Workers second guess themselves, slowing production. Often, additional injuries occur in the weeks following a LOTO accident as a result of kneejerk policy adjustments or changes to worker behavior.
Experts claim that for every dollar of direct expense that stems from a LOTO injury, anticipate up to four dollars in indirect expenses. In addition to weaker production, your corporate reputation almost always takes a hit in proportion to the severity of the accident. It is almost impossible to calculate the impact of negative press coverage, but anticipate at least some difficulty retaining employees and hiring talent as candidates reconsider the company’s commitment to keeping them safe. In the worst case scenario, a single LOTO accident can produce a dysfunctional culture where everyone points the finger at each other, and the entire work environment implodes.
All of these potential outcomes and others are possible when workers carelessly dismiss the significance of protecting themselves with LOTO.
LOTO as a Philosophy
How should you respond? Make LOTO the rule in every situation where the release of hazardous energy is a possibility, no matter how significant. Design procedures that anticipate all scenarios; include members from all departments (facilities, trades, operators, etc.) and work shifts so that risk assessments are detailed. Different perspectives will generate more thorough assessments, and all participants will feel invested in the process.
Create a corporate culture of no excuses. Be willing to stand behind the LOTO policy and penalize workers for ignoring it and managers for failing to make it a priority. Budget for the equipment required to make LOTO successful. Anticipate the man hours required to design, create and audit procedures.
Train. I repeat train.
Train employees on implementing the written procedures and periodically check to see that individuals retain their understanding of the diverse LOTO processes. Set aside time for employees to learn and practice. Be willing to retrain when necessary.
Finally, consider inviting third party safety experts in to your operation to offer you unique perspectives. I cannot tell you how often I have noticed a blatant hazard not addressed by LOTO. The mistake is never intentional, but workers and safety personnel become blind to scenarios and machinery they are exposed to everyday. Sometimes, I am even able to identify alternatives to LOTO that meet OSHA’s standard. On other occasions, I work with representatives to help engineer the maintenance/service issue out of production, so that LOTO is no longer required. OSHA admits to targeting LOTO due to the statistical risk for injuries/fatalities, so I encourage you to invite a safety consultant in to take a look at your LOTO program before an inspector arrives unannounced to take a look of his/her own.