Most facilities will have a few pieces of equipment that require using a dozen or more energy isolation devices to achieve a full LO’ed situation. Most businesses, at least early on in their implementation of LOTO for these pieces of equipment, will state ALL energy isolation devices will be utilized regardless of the scope of work being performed. This may seem like the “safest” approach, but what we typically find is that it leads to shortcuts that place authorized employees in serious harm.
For example:
The machine has 14 energy isolation points; however, the work I will be performing on the machine necessitates that I only need three (3) of them to FULLY PROTECT me based on my scope of work. Taking the simple approach and locking out all 14 energy isolation points will take 25 minutes; locking out the three (3) that I actually need will take 5 minutes.
Although the policy states to lock all 14 out, we can envision the policy being broken! Hence the title of this article… In a mature LOTO program, “SCOPE of WORK” matters.
How do we manage this aspect of LOTO?
The first step is to document the full LOTO using all 14 energy isolation points and the means to verify each isolation device was successful in achieving a Zero-Energy-State (ZES) was achieved for each energy source. Remember, the easiest method is to lock them all out. It may not be the most efficient method, but when ALL energy sources are at a ZES, we are assured safety.
But as we mature within our LOTO practices, we can begin to carve out specific tasks that are done routinely. These routine tasks are outside the minor servicing exception, so please do not confuse the two situations. The routine tasks I am speaking of are maintenance/servicing tasks requiring LOTO. But the frequency of these routine tasks, coupled with the policy that ALL 14 energy isolation points be LO’ed each time, begins to pressure the worker’s time metrics and the impact this has on production rates. And I can hear the grumblings already… “If safety is number 1, then time metrics and production impacts should not matter”. But they do, and we can have a HUGE win for safety by applying LOTO to the specific tasks being performed vs. simply locking out all 14 energy isolation points.
This approach REQUIRES the facility to have established SOPs and MPs! If the operators are not following OPERATING PROCEDURES in their daily tasks and the maintenance personnel are not following MAINTENANCE PROCEDURES, then we FIRST have to write these equipment/machine-specific operating and maintenance procedures BEFORE we can begin this approach to LOTO on the equipment/machine.
But once we have our SOPs and MPs in place, we can begin to specify which specific task(s) require which energy isolation devices to be FULLY PROTECTED while performing the servicing and maintenance. This approach will significantly improve the efficiency of LOTO while NOT compromising worker safety. However, this approach requires a lot of UP FRONT work to establish this type of management system within the LOTO program.