Anyone who has played sports or even just attended a team sporting event has heard or seen the famous saying:
There is no “I” in Team!
In our world of Lockout/Tagout (LOTO), nothing could be farther from the truth! There is not an act in occupational safety and health that is more self-serving and selfish than LOTO. Even in Group LOTO situations, LOTO is ALL about EACH WORKER having EXCLUSIVE CONTROL over 100% of the energy isolation devices protecting them. But here we are in the Year 2020 and already I have found workplaces that are making the critical error in assuming that only the “machine must be locked out” vs. “EACH WORKER having EXCLUSIVE CONTROL over 100% of the energy isolation devices protecting them”. This is a serious misunderstanding among our profession as the SAFTENG team has had numerous debates with safety professionals about the APPLICATION and IMPLEMENTATION of LOTO in their workplaces. I am shocked when a “safety professional” does not understand this most fundamental need in LOTO. In our 2020 Safety! presentation my good friend and safety rock Jonathan Zimmerman and I will be presenting “The Top 10 Myths and Misconceptions of LOTO” (Session # 5039) and guess what #1 will be?
LOTO is ALL about EACH WORKER having EXCLUSIVE CONTROL over 100% of the energy isolation devices protecting them!
And already, I can hear the grumblings in the crowd. How our profession has allowed this horrible LOTO myth to survive this long is puzzling.
We should NEVER ask or accept anyone asking: “Is the machine locked out?”. Rather, we should all be asking:
Employee #1: Do you have the machine locked out?
Employee #2: Do you have the machine locked out?
Employee #3: Do you have the machine locked out?
By asking the question “Is the machine locked out?” and only one of the three workers has it locked out, you will get an answer that will be incorrect!
I have seen it time and time again… the supervisor states we are doing an audit, and we just wanted to ask if the machine is locked out. All three (3) workers look up and nod their heads, and state, “Yes… of course, it is”. As the Supervisor begins to thank them as he walks off, I ask the supervisor why he/she is so confident in their response.
I will almost always get the defensive response of something like, “Safety is serious business here, and LOTO is the most serious of the business.” I admire the passion and desire for safety. Still, I saw some serious matters that need to be addressed, and what scares me the most is the fact that the supervisor continues with his affirmation for the safety of his team and how seriously he takes it.
So, what did I see that caused me to stop the audit?
Three (3) workers with their arms and heads inside a machine with all the guards removed, and on the power cabinet was a single LOTO lock. I was surveying the area looking for a Lockbox, assuming the team must have used a lockbox to perform the LOTO. I ask the supervisor to go back to the team, and rather than asking them if the machine is locked out, I ask each worker if they have it locked out. Make these questions DELIBERATE to each of the three (3) workers.
As the supervisor asks this question to each of the employees, it becomes very apparent as to who actually has their lock(s) on the energy isolation devices. You see, only one of the three workers applied their personal LOTO locks to the energy isolation devices. So when the supervisor asked them, “Is the machine locked out?” and they all answered yes, they were 100% factual and truthful in their response(s). We could see the looks of confusion on their faces when the supervisor asked each one the question.
The worker who had placed his locks on the isolation devices had been properly trained at his previous employer and he was the one who always locked it out, as he had actually been questioned as to why he was taking time to put his locks on the devices since “Gary had already done it“. This employee took his concerns to the safety manager ( a degreed and certified safety professional). He was told the program was solid and that OSHA had reviewed it several times.
The facility was even doing its “periodic inspections” and training as required by 1910.147, yet there was not even a hint that something was wrong. I was, of course, also dismissed, and the audit finding will be dismissed.
We have to dig into our practices to ensure EACH worker is PROTECTED. My Top 10 Rules of LOTO are intended to make this clear:
- LOTO is designed to protect YOU from the unexpected energization, startup, or release of stored energy.
- LOTO applies ANYTIME you have to remove a guard, bypass a guard, or place any part of your body into the point of operation during servicing or maintenance activities.
- Safety interlocks, light curtains, emergency stops are safety control circuits and are NOT to be used in lieu of LOTO during any servicing or maintenance activities.
- LOTO REQUIRES that a ZERO Energy State (ZES) be obtained. ZERO = ZERO!
- NEVER share or pass on keys to your LOTO locks.
- LOTO Locks MUST BE identified as such, either by shape, color or size.
- LOTO Locks can NEVER be used for anything other than LOTO (i.e. can not be used for personal security, production, quality reasons, etc.); other locks must be used for these efforts.
- LOTO Locks MUST identify who placed the lock on the isolation device
- NEVER use On/Off buttons or switches to perform a LOTO; these buttons/switches are NOT energy isolation devices but instead are “control” devices.
We MUST go back to the true energy isolation device for that energy source (i.e. electrical break, electrical disconnect, etc.) - ALWAYS verify ZERO energy BEFORE starting work (e.g. use pressure gauges, temperature gauges, try to start equipment, etc.)
We MUST make LOTO simple math:
three workers doing the work, then three (3) locks on EACH energy isolation device or
the lockbox method is used, and there are three (3) personal locks on the lockbox
Ever how it is done, EACH worker associated with the work MUST have exclusive control of EACH ENERGY ISOLATION device protecting them – EVEN in “Group LOTO”!
Now, some will argue with me, and that’s fine, and they will point to OSHA’s alternative methods, such as “taking a roll call” and such. But remember this: OSHA establishes MINIMUM safety standards. LOTO is an ABSOLUTE SAFETY CRITICAL safe work practice, and when we seek means and methods to reduce administrative control, we are asking for serious trouble. A $7 lock may mean the difference between life and death!