by Jonathan Poole
Safety Services Manager

Given Lockout/Tagout’s established place on OSHA’s annual Top Ten Most Cited Violations list, it is not surprising that I spend a lot of time as an EHS consultant responding to clients’ questions regarding the control of hazardous energy.  Regardless of industry or perceived corporate success, the majority of facilities nationwide struggle to effectively address the hazards associated with servicing, maintenance and other activities that require employees to bypass safety devices and reach their hands into machines.  29 CFR 1910.147 mandates diverse requirements and expectations concerning hazardous energy controls, but LOTO is just one of many safety challenges an EHS manager must confront.  What aspects of LOTO should you prioritize if your resources, like so many, are limited?

In my experience, five critical issues pose the most significant obstacles to successful LOTO efforts.  Assuming you have a written Hazardous Energy Program and can distinguish a lock from a tag, the next steps should be targeting the following issues and establishing a base line of basic LOTO understanding.  Once these challenges are overcome, your entire facility should acknowledge the necessity of hazard energy controls and recognize the purpose of locking/tagging out.

Issue #1:  With regard to hazardous energy, do you truly understand your onsite audience?
Because the LOTO standard was written with servicing and maintenance in mind, the employees it impacts the most are often the individuals who believe they understand hazardous energy the best.  Given their level of confidence, maintenance professionals regularly consider LOTO a nuisance, designed by safety professionals to needlessly waste their time.  Maintenance staff, after all, take the most risks, so why are they not more involved with developing safety policy?

Keep in mind that LOTO policies protect employees from unanticipated events. The standard addresses the idiosyncrasies of human behavior as much as it considers the threat of hazardous energy.  Before you find yourself in your next battle with the very people you are trying to protect, take a moment to involve the maintenance staff in the process.  At the very least, educate service team members and help them see that a LOTO program is not a commentary on their carelessness or ignorance, but an effort to safeguard them from others’ bad decisions and circumstances often beyond their control.  No one goes to work planning on having a serious accident. And with that in mind . . .

Issue #2:  When was the last time your staff, including Affected Employees, received LOTO training?
Controlling hazardous energy is not rocket science, but in the age of attrition, how certain are you that your facility’s new hires understand the purpose of LOTO?  Obviously, Authorized Employees that apply locks and tags should receive regular training.  Did you know, however, that many accidents involving the re-energization of machines occur because others unfamiliar with hazardous energy fail to recognize the intent of LOTO efforts and bypass precautions? 

While it may seem obvious, LOTO training must include everyone, particularly those individuals far removed from the operating floor.  Establish the expectation that locks and tags are sacred; no employee possesses the authority to remove another’s device or re-engage a machine that has been shut down for unknown reasons.  The sentiment you convey when training all staff re-enforces the concept that no one at your facility, including management, is above safety policy.  A LOTO program, like most safety policy, is significantly more effective when it is integrated into a facility’s entire safety culture.  

Issue #3:  How up-to-date are your LOTO procedures and when is the last time you inspected each?
Like forgetting training, many facilities lack Energy Control Procedures (ECPs).  These written procedures detail the steps and requirements for isolating all sources of hazardous energy to every machine in your inventory.  Unless the machine/equipment has one easily identifiable lockout source and never stores residual energy, OSHA requires a written procedure for every energy-powered component onsite. OSHA also requires annual periodic inspections of all ECPs to identify inadequacies or deviations associated with each.

Developing and maintaining ECPs can be the most difficult part of a Hazardous Energy Program because the process is time-consuming and never-ending.  Still, without procedures, employees must independently attempt to determine the sources of hazardous energy and location of isolation points.  ECPs drastically reduce risk by taking the guesswork out of the process, and every new component that arrives and qualifies requires one.  As important, OSHA expects you to periodically inspect ECPs every year.  Do you have a regularly scheduled process in place to comply?     

Issue #4:  How do you handle minor servicing and document exceptions to LOTO?
Implementing a Hazardous Energy Program is a thankless endeavor, but nothing is perhaps more disconcerting than the efforts of others to establish loopholes to safety requirements.  Since ECPs are only as effective as the employees that choose to follow them, consider your audience once more.  1910.147 is primarily designed for maintenance staff, but remember, machine operators often qualify as Authorized Employees as well.  Operators routinely bypass guards and place their hands at the point of operation to clear jams and perform other minor servicing activities.  These workers will challenge LOTO procedures as frequently as your maintenance staff.  Do you have a policy in place for distinguishing minor servicing and defining which work activities do not require LOTO?

The decision as to what maintenance and servicing tasks qualify as “minor” is a timeless debate.  Do not pursue it down the rabbit hole.  Establish lockout/tagout as the standard.  Then, as minor servicing opportunities present themselves, debate the merits of which activities can be performed safely with the support of Alternative Protective Measures (APMs).  Minor servicing procedures will require the same level of training and documentation as LOTO, so remind your staff that most efforts to avoid lockout/tagout do not result in a huge savings of time.  After discussing the risks involved for each task in question with the personnel directly impacted by the activities, determine which activities qualify (routine, repetitive and integral) and have the employees design a procedure that EHS can then critique.  Continue the process until a documented procedure is created that provides the same level of protection as LOTO.  If that is ultimately impossible, the “minor” servicing label fails, and the activity does not qualify as an exception.  Convenience should never be the reason APMs are substituted for LOTO.

Issue #5:  What is your enforcement policy when an employee neglects to implement lockout/tagout?
No matter how effective your Hazardous Energy Program appears, if it lacks consequences, it will ultimately fail.  Typically, the consequences of ignoring LOTO are accidents, and those outcomes bring with them both price tags and lifelong disabilities.  To ensure your workers avoid becoming statistics, it is up to you to incentivize the behavior you expect. 

Like it or not, the strongest LOTO programs offer zero tolerance and sometimes result in the terminations of employees who refuse to comply with corporate safety policy regarding hazardous energy.  Since qualified workers are in short supply (maintenance staff and machine operators particularly), there is the tendency to look the other way when colleagues ignore LOTO.  If this sounds like your facility, reconsider the response.  Accidents do not happen every time risks are taken, but eventually the law of averages results in catastrophe.  A single injury or fatality can trigger consequences that include OSHA investigations, bad publicity, worker distrust, increases to worker compensation rates, etc.  Be careful how you address hazardous energy failures because the message you send communicates to the entire staff your commitment to enforcing LOTO in the future.

When placed into context, dismissing an employee for failure to LOTO can potentially save lives and impact the bottom line.  It sets an example for safety expectations and if handled properly, establishes a facility’s commitment to protecting its workers.  Many facilities balk at penalizing staff and insist on re-education, but I remind you that accidents involving uncontrolled hazardous energy are rarely minor events.  If you want to impact a broken safety culture, consider integrating employee consequences at the same level as the threat to employee safety.

Hazardous Energy Programs present challenges to all facilities, including those that strive for the safest work environment possible.  If you want the most bang for your buck, focus your LOTO efforts on these five essential issues. EI’s LOTO experts also provide LOTO training, procedure development and EHS consulting services that can help you update your Hazardous Energy Program and make it an asset instead of a liability. Need help?  Contact Jon Poole, Safety Services Manager with The EI Group at (919) 995-3504 or [email protected].