5 Components in Building a Safe Lockout/Tagout Program

OSHA COMPLIANT

OSHA reports that one of the top 10 most frequently cited standards following inspections is the control of hazardous energy, also known as Lockout/Tagout. EHS Today identifies the most common Lockout/Tagout violations within these citations as failure to provide LOTO training, to create equipment specific LOTO procedures, to conduct periodic LOTO inspections, to establish a proper LOTO program and failure to develop and enforce a LOTO policy. EHS Today also reports nearly 3,000 LOTO violations were recorded in 2019. These preventable citations had fines that averaged around thirteen thousand dollars per violation.

An OSHA compliant LOTO program is important to ensure that proper safety guidelines are in place and procedures are up to date to avoid unnecessary citations. However, the most vital aspect of an OSHA compliant LOTO procedure is to reduce electrical hazards and keep workers safe. Providing a clear and defined LOTO program with appropriate training protects workers from severe injury and, in some cases, death.

BUILDING AND MAINTAINING A SAFE LOTO PROGRAM CAN BE BROKEN INTO 5 COMPONENTS

1. Policies - To start, a LOTO program must have a written policy that gives procedural steps that can be used to safely carry out LOTO procedures. The policy needs to identify who is authorized to perform the procedure, steps to de-energizing equipment and where LOTO devices should be placed. Authorized employees should be listed in the policy by their name, position title and/or level of knowledge and experience required to carry out the procedure. The policy should then describe the steps on how an authorized individual would go about properly shutting down, de-energizing and securing equipment. Finally, the areas of isolation should be identified and listed so that proper LOTO devices can be placed. These LOTO devices must have a dedicated person to place and remove them to avoid accidental re-energization of equipment.
2. Device Procedures - All devices must have a set of clearly written, equipment specific LOTO guidelines with step-by-step procedures for controlling a device's hazardous energy visually available on the device. These procedures must include all the necessary steps for workers to remain safe before, during and after shutting down a device. Graphs, lines, photos and drawings are also acceptable on procedures to demonstrate processes. If new equipment is added to a device's machine line that directly impacts the established step-by-step process, the procedure must be revised and replaced with an updated copy as quickly as possible. Procedures must be checked every few months to ensure accuracy with OSHA standards and device regulations.
3. Safety Equipment - Providing the right safety equipment, such as the correct locks and tags, is vital to maintaining an effective LOTO program. Locks specifically made for LOTO purposes should be applied at isolation points by an authorized employee. These locks should only have one owner and are only to be placed or removed by the lock's owner, or in rare cases, a safety supervisor. After locks are placed, tags should be placed on the energy source of the device that is being worked on. The tag should include important information such as energy source location, magnitude, device type and source isolation points. LOTO devices should be regularly inspected and regulated to ensure quality and consistency.
4. Training - All authorized, affected and other employees are required to go through the proper LOTO training to ensure user safety. Training should include information on how the procedure will impact the employees working in the area, the type of work being performed and the hazards involved. Other trades or employees not involved with a specific LOTO procedure also must be informed of the work being done in the area. When there are any changes to the type of work, equipment or processes, retraining must be provided to avoid potential safety hazards.
5. Program Auditing - LOTO programs, procedures and training must be reviewed and updated frequently. OSHA states, “Each energy control procedure must be separately inspected at least annually to ensure that the energy control program is being properly utilized.” LOTO programs should be carefully reviewed to ensure all the necessary steps are accurately listed to be current with OSHA and facility safety standards. Individual equipment procedures must also be reviewed to ensure accuracy, especially if changes occur to a device's configurations or machine line. Annual audits should also include reviewing authorized employee knowledge and training. Inspection of an employee's ability to correctly carry out LOTO procedures will indicate the need for additional training or, in some cases, retraining.

These five components help build a solid foundation for an effective LOTO program. Having a clear, written LOTO program with policies, device procedures, proper safety equipment and training is essential to keep employees safe in situations where energy control is necessary. However, the key to maintaining the effectiveness of a LOTO program is consistent reviews and updates to the components. Many companies struggle to update their current program and procedures because they lack the resources to allocate, such as time or manpower. When this happens, procedures and policies become outdated, employee training is not adequate for their working conditions, OSHA regulations are no longer being met and the workers are at risk for severe injury or death.

To combat this issue and prevent lapses in LOTO programs, Kirby Risk offers customizable solutions designed to fit customer needs. Michael Cleaver, Kirby Risk Automation Specialist states, “A lot of the customers we work with have a LOTO program in place but haven't had time to keep it updated, behind on OSHA compliancy or they don't have the right employee training in place. Our team comes in and assesses everything, creates or updates procedures, walks through training and identifies next steps for how the customers can maintain the program moving forward.” As a Rockwell Automation Service Provider, our qualified Kirby Risk Service Technicians will guide customers through all five components of our LOTO services . Rockwell's safe and efficient LOTO solutions administered by Kirby Risk provide customers with ease of mind, ensures OSHA compliancy, proper employee training, frequent auditing and quality safety equipment.