Last month, I discussed what a “management system” would look like should we manage our Permit-Required Confined Space entry operations as a “management system” versus a standalone OSHA compliance program. (CLICK HERE for that post)
Today, I want to discuss the same approach but in respect to how we manage another life safety critical practice… The Control of Hazardous Energy is better known as Lockout/Tagout (LOTO). As of this writing, I have written about LOTO 187 times, most of which are on the technical side of developing, implementing, managing, and auditing LOTO programs and procedures. In this article, I want to take a 35,000-foot view of how a an Energy Control Program should be managed by those closest to the action. So here is the outline of what I will be discussing:
1) Written Program
2) Machine/Equipment specific energy control procedures
3) Training
4) Periodic Inspections
5) Auditing
And, of course, I will again use the PLAN→DO→CHECK→ACT model to wrap our heads around this topic.
Written Program
This is where it all begins! The foundation from which we will build our LOTO element of our safety management system (SMS). To the shock of some, this written program has many decisions that need to be made, and those making those decisions need to understand the impacts of their decisions. For example, OSHA allows employers to choose Lockout (LO) or Tagout (TO) as their preferred means to control hazardous energy sources while servicing and performing maintenance on machines/equipment. LO is OSHA’s preferred method; however, they allow a facility to use TO when the employer can demonstrate that their TO approach is EQUALLY EFFECTIVE as a LO approach. OSHA uses a term called “Tag+,” meaning that when TO is the means to secure energy isolation devices during servicing and maintenance, at least one (1) additional action must take place for the TO to equal LO.
Management must also understand the scope and risks of implementing the “minor servicing” exception to LOTO. This alone can be an entirely mini SMS as we have to:
- Identify the tasks that meet the five (5) criteria that have to be met to declare a task as “minor servicing.”
- Part of Normal Operations
- NO disassembly
- Routine
- Repetitive
- Integral
- Analyze the hazards associated with these tasks
- Perform a risk assessment so that we can ensure our ALTERNATIVE means of protection is equal to LO
- Implement and maintain the safeguards called for in the risks assessment so that the employee is protected as if they have LO’ed the energy sources.
Utilizing the minor servicing exception means we will need a “maintenance program” for these “ALTERNATIVE” protections, as they must be designed, installed, and maintained per some recognized code/standard. Understand that if this “exception” is not appropriately managed, it will be like a cancer in our LOTO programs, and it will become the practice rather than an exception. This means we need a FORMAL process for management to request a Hazard Analysis and Risk Assessment on a task that operations/maintenance feel could be performed as “minor servicing.” Then, it is the Subject Matter Expert’s (SME) role to perform the HA and RA and inform management of the level of controls necessary to perform that task without the aid of LOTO and instead under the ALTERNATIVE MEANS of PROTECTION that will equal that of LOTO. ALL these tasks are DOCUMENTED, managed, and maintained by the OWNERS of the machinery/equipment for which they apply.
The written program also MUST identify our LO locks by:
- Color,
- Shape, or
- Size
This is intended to ensure ALL personnel (Affected, Authiorzied, and Others) can identify LO locks. This simple requirement is often not DEFINED in the program. Instead, the program regurgitates the exact language from 1910.147(c)(5)(ii)(B).
The written program also MUST identify WHO, WHAT, WHEN, WHERE, and HOW the following aspects of energy control will be managed:
- Machine/Equipment specific energy control procedures
- Training
- Periodic Inspections
- Auditing
Machine/Equipment specific energy control procedures
These play a critical role in controlling hazardous energy during maintenance and servicing tasks that require a worker to remove or bypass a guard or defeat a safety device in order to place a part of their body into the machine’s hazard zones. These energy control procedures will be specific to the machine AND the actual tasks. This means that a single machine may have multiple tasks that get performed, which involve DIFFERENT energy sources that need to be controlled.
However, it is critical that the program identifies (by job title – NEVER by name) WHO is responsible for these machine-specific procedures. Understand that this is usually multiple people, as the Department Manager usually owns this role and responsibility.
However, the safety pro usually creates the template for these machine-specific procedures. The safety pro is usually the SME who DEFINES which machines/equipment require a specific procedure, as NOT every single asset will fit into OSHA’s image of a “machine-specific procedure” (e.g., a chemical process with thousands of individual valves). But when these valves have to be worked on/changed, this work REQUIRES that an energy control plan be developed based on the SCOPE of work. When we are “opening our process,” this will fall under our Line Break and Equipment Opening procedures, in which LOTO plays a significant role. But this aspect of a LOTO on a “complex process” needs a written program or procedure to guide the crews who need to develop their energy isolation control plan WHEN there is NOT a specific procedure already on the books for their scope of work.
Training
I go back to my WHO, WHEN, and WHAT mantra!
Who needs to be trained in LOTO safe work practices? Employees and Contractors is the simple answer, but their training may vary wildly depending on their roles with the program. There are essentially three (3) buckets of workers in LOTO:
- Authorized
- Affected
- Other
Which bucket these workers get placed in will define their level of training. But pretty much everyone on the site will go into one of the three buckets.
The level of training each group/bucket will need is based on their level of involvement. I can train most “affected” and “others” in 30 minutes. But an “authorized” employee will take anywhere from 2 hours to 12 hours (done over days). This can even be longer when the authorized employees will perform maintenance/servicning on assets that do NOT have “specific procedures”. These workers need to be trained to a level they can IDENITFY:
- Hazardous Forms of Energy
- their magnitude
- the means/methods to properly isolate them
- the means/methods to verify the isolation were successful in achieving a Zero Energy State (ZES)
When and how often is all of this training to be done?
Many people falsely believe that OSHA requires LOTO training on an annual basis, and that is INCORRECT. OSHA only requires:
- initial training
- training when the program has been changed
- training when an authorized employee fails their “periodic inspection.”
So that is the MINIMUM we must meet, but many employers wish to do training more frequently. This is fine; it just needs to be QUANTIFIED in the program.
What do we cover in the training?
Remember, we have three (3) buckets of workers with varying roles in the LOTO functions, so it is only logical that we would have three (3) different training programs for these groups. 1910.147(c)(7) provides the minimum that needs to be in the training curriculum, but this is the OSHA minimum. My preferences in meeting 1910.147(c)(7)(i)(A) is to cover this when the “machine specific” procedures are trained on.
Periodic Inspections
In my p[professional opinion, this is the CRITICAL path in any LOTO program, and unfortunately, these inspections are often NOT done at all, and when they are done, they are “pencil whipped,” which badly misleads management into thinking all is well with LOTO. I see a lot of debating on the scope and application of “periodic inspections.” However, these inspections/audits are our means to verify that the procedures are correct and that workers can utilize them properly, and they are doing so each time they perform maintenance/servicing.
1910.147(c)(6) specifies the required documentation for each inspection/audit, but some employers may want to gather more data to better understand the cause of any failures.
The program needs to explain how this data will be analyzed BY WHO and how often and WHAT do we do when we identify gaps in the program, training, inspections, etc. The inspections are critical, but what we do with the data gathered from the inspections may even be more critical.
WHO does these inspections needs to be DEFINED. Those who do them will need TRAINING on how to perform an inspection and document these inspections. I have always believed that the supervisors of authorized employees should be performing periodic inspections, with safety doing some random inspections to establish a baseline that should be in line with the inspections performed by the front-line supervisors. (see auditing below)
Auditing
This is NOT an OSHA requirement; however, this is how we ensure all the elements discussed above are being implemented and managed correctly and per the requirements of the written program. I did my audits quarterly and almost always found “gaps” in managing the elements. I just chalked these up to continuous improvement opportunities.
I believe that these audits should be performed by SME’s in LOTO, as these are looking at every aspect of the program. 2nd and 3rd party audits bring in a new set of eyes that may find items that the program owner or in-house SME may overlook. But for sure, the facility safety personnel should be ROUTINELY auditing the functions of the program and then compare this to the data from the peroidic inspections.
The last topic we need to discuss is NEW machine(s)/equipment(s) or CHANGES to machine/equipment. WHO performs the HAZARD ID, HAZARD ANALYSIS, Risk Assessment, and Risk MITIGATION on the new or changed machine? Safety can be involved, but often, safety will never be informed of these changes, so OWNERSHIP needs to fall on the OWNER of the machine/equipment. These requirements can reside in a separate program, but I always covered them in my LOTO program, as we can not talk about LOTO without talking about guarding and safeguarding of the hazards associated with the machine/equipment.