I wrote about “focusing on our fundamentals” this week, which generated a lot of discussions offline amongst my friends and clients. The number 1 question asked was “What should we score in 2026?” My response was “at least 95%”. That means that in 100 LO inspections, we should have a failure rate across ALL items within each inspection of 5 out of 100.
Does anyone think this is an unreasonable expectation in 2026?
If we encounter serious issues, such as a failure to apply LOTO, that would be a showstopper, and we would investigate how that could happen in 2026.
In February of this year, we were asked to perform a detailed audit of a facility’s LO practices. The facility had 3 serious injuries and a near-fatality in just 4 years. The new PM, an old friend and client throughout his career, reached out for help when he took on this new role.
The company had taken many actions after each event, but many of us would call those actions “window dressing,” and far too much emphasis was placed on “the worker” failing in some manner. Sound familiar? So he wanted an unbiased examination of the entire LOTO program/process at his new plant.
We always start with the “written program,” and like many, it was simply a regurgitation of .147. I scored it a 2/10, mostly because the backward approach to minor servicing required no alternative protection for the tasks, and on top of that, many of the tasks were NOT part of “normal operations,” and most everyone knew it; they simply failed to recognize the issue/risks and the limitation of the “minor servicing” exception.
But the biggest failure, one that is far too common for many facilities, is the abject failure in “periodic inspections”. After each major event, corporate came in and walked the floor with facility management, conducting a “periodic inspection” of every authorized employee on first shift, and at each event, they found very little to note. Now, to be fair, this could have been driven by a short-term change in workers’ behavior, and once they were gone, things went back to “normal”.
But when my team went out to inspect procedures and practices, we had an overall score of 3/10 across 268 inspections. No inspection received a perfect score of 100%. In some cases, the procedure was not even close to being correct, but no worries, as workers did not bother to use them. We found workers who had never even been trained in LO locking out equipment at the facility. People using locks that were not a LO lock or even their LO lock. People working under LO who were not part of the LO (I.e., they did not have it locked out but their partner had it locked out) and the one that really scared us, we found numerous people working under a LO, and the energy source(s) were not at a ZES (mostly involved stored energy issues with gases such as air, N2, and steam). NOTE: Two of the amputations and the near-fatality involved stored energy, so yes, we were zeroed in on those failures when we began our inspections. And the facility has supposedly abated those concerns by closing out their OSHA citations!
We found all of this in a single week across three shifts. We also found workers inside PRCSs without a permit or a reclassification form. The contractor LO was worse; I said it was totally absent, but management pointed to a single contractor who had a lock on a lockbox as proof it wasn’t. Please note that on the third shift, 99% of the workforce in the plant are contractors doing cleaning; so 1 out of 200+ is a total absence in my book. Plus, when asked why he was on the lockbox, the contractor knew to LO from his previous work at his previous employer’s, it was NOT because the host facility made him!
So I ask you, how can a facility that has been in operation for 57 years be this bad in LOTO in 2026? Especially with all the previous exercises from previous incidents?
What should be our performance expectations in 2026 for our safety fundamentals, such as LOTO?
Should we be implementing new, shiny programs such as BBS/SIF when our fundamentals are so far off base? Are they not a drain on our limited resources that would be better spent mastering the fundamentals?
We spent the last half day training EHS, Ops management, maintenance management, and the engineering group on how to conduct a real “periodic inspection” and how to properly assess “minor servicing” opportunities. The vast majority were appreciative of the training, but we still got some “eye-rolls” and outspoken concerns as to “what’s all this going to do for our production demands”.
In 2026, management should engage in hands-on activities with plant workers on safety fundamentals. Workers can see this happening, which reinforces the mindset that safety matters and enables us to achieve continuous improvement through the exercises. We just need to train/teach management what to look for in each specific walk. Pick a topic and focus on that topic for the walk. Let the EHS pros identify all the other issues we see, but keep the management team focused on the fundamental item during the walk. They learn, things improve, and workers witness this all firsthand!
These walks are NOT an enforcement action- they are a time to work together and UNDERSTAND WHY we are seeing the issues we are seeing. The idea is to IDENTITY AND IMPROVE.
Please make these walks and the closure of the corrective action plans (CAPs) that come from them a “Leading indicator” in our safety metrics. Heck, I even tied them to my management “incentive plans” as we moved away from rewarding for injury rates and more on participating in “safety activities.”