How did you spend your Friday night and Saturday? Me? I spent mine helping a client manage a traumatic injury to a new employee with less than 3-weeks on the job. And like most employers, this company truly cares about their employees and honestly wants the best for their employees. This business may be the last of the companies that cover 100% of the insurance costs for their employees; the CEO spends about half her time in the plants and at safety committee meetings listening to employees and engaging in the safety solutions. So how could this type of workplace fall prey to a LOTO accident? Easy, they, too, are having difficulty finding employees to meet their production demands! The company had slowed production because of too many incidents/accidents weeks before this incident, but that was not enough – employees had already established how to cut corners to meet the production demands, and those “habits” were well in place. But this organization stepped up and performed the investigation, leaving no rock unturned, and they know what is going to most likely happen on Monday when OSHA arrives. Here is how this LOTO Failure accident occurred – every workplace has done this with varying degrees of failure and why being “Authorized” means something in LOTO.
In 2016 SAFTENG was hired to perform a safety assessment/audit for this facility. Like many privately owned businesses, there was an “internet acquired” safety manual in place but no functioning safety process.
This specific facility manufactures “widgets” and then packages these “widgets” for all the different brand names the “widgets” are sold under. These widgets are an everyday item in households around the globe but are made in the USA. So you can imagine the price/cost constraints placed on this small business that is also struggling to hire enough workers to maintain production. If they lose the “widget” business, this rural plant will change the entire community in which it operates, as there is no other employer with career-type jobs. Sound familiar?
In 2016 we took over their safety and wrote site-specific safety programs, instituted safety committees (required in this state plan), put metrics in place so management can monitor the safety process, etc. As you can imagine, training was a huge effort in the process. The business fully supported the in-depth training we conducted, realizing that most of their employees had never worked elsewhere, so the programs, training, and approach to OSH would be vastly different than anything they had experienced. Luckily two senior managers were hired in recent years from larger businesses where a similar “safety program” approach was in place. These two were quite familiar with this approach and knew this was the “first step” in establishing safety at the facility.
In my professional opinion, Lockout/Tagout (LOTO) is undoubtedly the backbone of a safety program in a traditional manufacturing environment. I was raised by my safety mentors and coaches that DETAILS MATTER in all Life-Safety Programs. And anyone who has ever worked with me, and my SAFTENG team knows just how seriously we take LOTO. We take a very structured approach, using the framework provided by 1910.147 and then exceeding OSHA requirements to ensure our clients get all they can from their LOTO practices.
In our LOTO world, we have three (3) buckets of workers:
1. Affected
2. Authorized
3. Others
I have written over 150 articles about LOTO, and in just about every one, I speak about how we need to manage these three groups, as this is critical to having a successful LOTO program.
Today we will discuss the Authorized Group and how being “authorized” within the LOTO program means a heck of a lot – it is a BIG DEAL, maybe the biggest step in a traditional LOTO program. There is a HUGE difference between being an “affected employee” and an “authorized employee,” and unfortunately, this simple fact causes tremendous confusion among many employers.
In our SAFTENG LOTO approach, being an “authorized employee” means you are authorized to perform LOTO on ONLY those machine-specific energy isolation procedures you have been trained on. For example, you are trained as an “authorized employee” on Line 1 within the facility and thus you can perform LOTO on Line equipment; however, you are NOT “authorized” on Lines 2-7 and 9-10. Line 8 uses a different brand of machinery; however, the energy types, their magnitudes, and most importantly the energy isolation devices are the same as Line 1. So officially, an employee would be “authorized” on both Line 1 and 8.
But to become an authorized employee, you must first attend the 3-4 hour Authorized Employee training class. In this class, the student is introduced to:
1) type of and magnitude of the Hazardous Energy in the facility
2) the isolation means and devices used in the facility, including the proper operation and application of the energy isolation devices
3) the means to very the applicable energy sources are at a zero-energy state
Remember that almost none of these employees had ever seen a valve lockout device, breaker lockout device, cord-plug lockout device, a group lockout hasp, etc. We train them on installing each type of lockout device on the energy isolation devices used in the facility. This course is simply to get them ready to be trained on the machine-specific LOTO procedures on which they will be “authorized” to execute.
Once they have a fundamental understanding of the energy types, their magnitude, the means to isolate and verify ZES, using the proper Lockout Locks, etc. they graduate to the “floor” for their next level of training in becoming an “authorized employee.” And I should also state, that not everyone hired goes through this 3-4 hour course. Most employers have chosen to segregate their employees into these three (3) LOTO buckets, which are also loaded up with risks if not managed well. For example, management is not disciplined by moving employees around based on production needs. They take the approach that if an employee can run one machine, they can run any machine, and they also take the approach that if an employee is “authorized” in LOTO, they are “authorized” on every piece of equipment. And that is usually NOT the case!
In this weekend’s accident, the employee was an “authorized” employee; however, this was just the “magic wand” approach, as he/she did not attend the “authorized employee” classroom course, nor did they receive training on the floor with the machine-specific procedures associated with the line(s) he/she would be operating. LATENT FAILURE #1
The employee had a long history of LOTO, and when we interviewed him/her, it was clear former employers had trained them on LOTO. However, he/she had zero experience applying their LOTO knowledge to these types of machines