If we look close enough, we can see OSHA’s approach to some of its more extensive standards through the lens of its fitting into a formal Safety Management System. The Control of Hazardous Energy (e.g., Lockout/Tagout) standard is one of these standards. Using the old Plan→Do→Check→Act SMS model, we can breakdown 1910.147 into this model, which is an excellent fit.
Planning
The first step in developing and implementing a LOTO program is establishing the SCOPE and APPLICATION of the facility’s program. Most traditional manufacturing facilities will have the ability to have many “machine/equipment specific procedures”, whereas not all Lockouts (LO) will be that simple, and thus there will be a need for a means to develop specific procedures for complex and large systems based on the scope of work taking place. Part of this development of the program will establish who is responsible for the generation and maintenance of these specific procedures, who is responsible for maintaining the LOTO equipment (e.g. Lockout devices), who is responsible for training the three different groups (including contractors), and who is going to be responsible for the periodic inspections. LOTO is one of the OSHA standards that impact nearly every worker within the business almost daily (when the program is implemented correctly and used correctly), so it is not easy to develop, implement, and manage. So this up-front planning/mapping out who, what, when, where, and how is critical in a successful launch.
Do
This should be self-evident; once we have developed and implemented the program, it is time to start living the LOTO way of working. it may sound simple and easy, but it is far from either. Usually, the first glitch that will arise will be workers doing what they have done in their daily routines with their machines/equipment. Sticking your hand inside a machine numerous times a day for years and never experiencing a negative consequence, in fact, that act has produced favorable outcomes, is a very hard habit to break. It takes more than a training session or two to break these unsafe habits, so expecting “we told you not to do X any longer” is NOT how we change behaviors or implement LOTO. There will need to be an intense coaching/auditing schedule to ensure that workers are afforded the opportunity to understand what they learned in training and how it actually impacts their daily interactions with their machines/equipment. Trust me – there is always a significant disconnect between what they heard and saw in the training and how they translate that into their daily work functions. Disciplining workers who fail to fully embrace LOTO once they are back in their regular job is NOT a good idea; this may come later for those who can’t get on board.
The next major hurdle to cross is always the “minor servicing” exception. When chaos begins, AND IT WILL HAPPEN, once workers begin to complain to supervisors and supervisors begin to use LOTO as their excuse for all the production and quality issues, management will begin to push back on LOTO and the claims of “this is going to bankrupt us” will be said. It will be critical that the minor servicing “exception” stays as an exception and does not be the “rule,” which usually happens if this is not developed, implemented, and managed properly. PLEASE see my other articles on the “minor servicing” exception.
Check
This is the CRITICAL PATH in all LOTO programs. OSHA was wise to require this in its standard, but unfortunately, it is often abused as a “check the compliance box” exercise rather than a critical safety path in the SMS. The LOTO standard was one of the first OSHA standards that actually requires some means to verify the program is functioning as expected.
In fact, OSHA even set up the standard, so that as long as the authorized employees can DEMONSTRATE they fully understand the program and how to utilize it to control the hazardous energy they could be exposed to, then they do not have to receive “annual training,” which most standards just dictate annual training. This means LOTO is a “performance-oriented” standard… an authorized employee passes their annual inspection (audit), they are good; if they fail their annual inspection (audit), then they have to receive training to correct their failures.
Please keep in mind that when we find a trend in our inspection/audit results, this trend is most likely NOT a reflection of non-compliant behaviors, but rather more likely a flaw in the implementation and/or training.
The periodic inspections function should include the following:
1) a review of all the machine/equipment-specific procedures – when facilities claim we have hundreds of these procedures, I remind them there are 365 days in the year, and the facility operates 360 days per year, 24 hours a day. There is plenty of time to perform these reviews; it just needs to be significant enough to want to do it. In its minimum compliance approach, OSHA allows for “like procedures” to be grouped to meet their minimum expectations. I call BS on this – no grouping in my world – I have seen far too many mistakes go unnoticed until someone suffers a consequence!
2) every authorized employee gets an inspection/audit each year – when LOTO is being executed well, these inspections/audits could take around 10 minutes; some may take longer when the LOTO involves multiple lockout devices and types of energy sources. I have always put the responsibility of the annual inspection/audit on the employee’s supervisors, with a verification step done by the safety team to ensure the supervisors perform their inspections/audits properly and the results match up.
3) the overall LOTO program is reviewed to ensure compliance and reflects how LOTO is managed within the facility. This can be done via 3rd party, whereas #1 and #2 above must be done in-house.
Act
Of course, after our annual inspections/audits, we MUST address the deficiencies and other identified opportunities to strengthen the programs and practices. These corrections and improvement opportunities need to be FORMALLY developed and tracked to closure. Some of these activities will span the entire facility, so how they are managed plays a critical role. For example, a program change will likely need to be managed via our Management of Change process and then each Department/Unit at the facility will be responsible for rolling out the change within a prescribed time frame. I always assigned these actions to the Department/Unit Manager; although they typically are not the ones doing the actual work, it is their responsibility to ensure they allocate the necessary resources to implement the change(s). Of course, the facility safety team is one of these resources, but we are NOT responsible for implementing the changes across the facility.
The Act function also covers “new employee” training which is a regular activity these days with all the employee turnover. How a facility takes a new employee from nothing to being an Affected Employee and/or Authorized Employee should be part of the Planning function, as it could be a significant hurdle for some facilities. I always approached LOTO training as both an educational and a hands-on session in the plant, applying devices to energy isolation devices. Who does which part or all must be decided in the planning phase. It is not unusual for us to find an energy isolation device improperly locked out simply because the worker was never shown how to apply the lockout device to the isolation device properly, so they did the “best they could.” So training on the written program requirements, where we teach the scope and application of the program, is Step 1, but Step 2 is the hands-on field training using the devices they will need to lock out their machines/equipment. NEVER assume this needs only “common sense”; many of our students today may have worked in a business that never used LOTO or were never in a role where they received adequate training.