Last month I wrote a few posts about how a compliance manual made up of dozens of individual safety programs written for OSHA compliance needs is not a safety management system (SMS). That post got a lot of friends to encourage me to expand on that position and explain what I meant. So using one of my favorite OSHA standards, I want to demonstrate how Lockout/Tagout (LOTO) can indeed be managed as its own miniature SMS and how this fits into the more significant SMS for the facility.
Complying with OSHA’s LOTO standard (1910.147) is a never-ending cycle of Plan-Do-Check-Act. This simple fact makes the standard mimic a SMS built upon the same model. So how does LOTO follow the PDCA model?
The standard requires a written program that implies “planning.” The purpose of the written LOTO program is to establish the who, when, and how LOTO is going to be applicable and managed. LOTO is fully intended to be a SITE-SPECIFIC program that identifies the who, when, and how. OSHA even goes as far as the program identifying LO locks by color, shape, or size. So the written program is intended to explain the who, when, and how in great detail. It is the planning phase in the PDCA cycle.
The DO stage of the PDCA cycle is the actual execution of LOTO (how it is done and by who).
The CHECK stage of the PDCA cycle is where OSHA drove the SMS approach to their standard. Let’s look at the CHECK aspect of the standard – noting that this requirement in the standard has been in the Top 3 requirements cited for LOTO violation since the promulgation of the standard.
The first place we see mention of this “CHECK” requirement is… (emphasis by me)
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1910.147(c)(1) Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and PERIODIC INSPECTIONS to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source, and rendered inoperative. |
So the standard requires the written program to include these periodic inspections. Although OSHA uses the word periodic, these are annual requirements. Let’s not hang our safety cap on an OSHA LOI or CPL and justify anything lesser, as all that does is place us inside the compliance box – NOT world-class safety.
The next place we see OSHA mention “periodic inspections” is…
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1910.147(c)(6) Periodic inspection. 1910.147(c)(6)(i) The employer shall conduct a periodic inspection of the energy control procedure AT LEAST ANNUALLY to ensure that the procedure and the requirements of this standard are being followed. 1910.147(c)(6)(i)(A) The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected. 1910.147(c)(6)(i)(B) The periodic inspection shall be conducted to CORRECT any deviations or inadequacies identified. 1910.147(c)(6)(i)(C) Where lockout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee’s responsibilities under the energy control procedure being inspected. 1910.147(c)(6)(i)(D) Where tagout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section. 1910.147(c)(6)(ii) The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection. |
Here we see some specifics in when and how these “CHECKS” are to be done. These “periodic inspections,” as OSHA calls them, are intended to be the means to verify LOTO is functioning as defined by the written program AND the machine/equipment-specific energy control procedures. It is a KEY and CRITICAL piece of the LOTO management system. Without this activity, we do NOT have a SMS – we have just a written program with training. These inspections are what make the LOTO standard a PDCA model. In my programs, we divided the number of Authorized personnel by 12 (12 months in a year). We then established a goal of how many inspections were to be done each month to ensure that at the end of the year, we would have met the OSHA minimum. We used this inspection goal as one of our leading indicator KPIs – it was that important to us. NOT to make OSHA happy but to have confidence that LOTO was functioning as intended. LOTO was always one of my Life Safety Programs, which meant we built leading indicator metrics around the program, again helping cement that the program was more a SMS than just a written program.
The last piece of this model is the ACT piece. It, too, is KEY and CRITICAL to a successful LOTO program. OSHA defines when management MUST ACT…
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1910.147(c)(7)(iii) Employee retraining. 1910.147(c)(7)(iii)(A) Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures. 1910.147(c)(7)(iii)(B) Additional retraining shall also be conducted whenever a periodic inspection under paragraph (c)(6) of this section reveals, or whenever the employer has reason to believe, that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures. 1910.147(c)(7)(iii)(C) The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary. 1910.147(c)(7)(iv) The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee’s name and dates of training. |
Many organizations will perform LOTO training annually, even though this is NOT required by the standard; however, many organizations are NOT doing these periodic inspections. And OSHA has clarified that annual training is NOT a substitute for periodic inspections.
So there you have it, LOTO in the PDCA model of an SMS. If we could begin to view LOTO as a SMS and not just a written program that sits on a shelf and rots we would make huge improvements in our efforts to control hazardous energy during serving and maintenance. LOTO is a safety tool – NOT a hindrance. It saves lives!