Some of you may recognize these suggestions, but for those unfamiliar with them, I will wait and surprise you at the end of this article to find out where these “suggestions” came from! Nonetheless, any workplace utilizing Lockout/Tagout (LOTO) should consider implementing these into their existing program. For those in the General Industry, many facilities struggle with these kinds of details, but they are ESSENTIAL to what I believe to be one of the top 3 core safety processes within any workplace! Here are the program suggestions:
Incident investigation
The Department Manager responsible for the area and/or the personnel involved and/or impacted by the incident shall investigate each incident that resulted in, or could reasonably have resulted in, energization or startup, or the release of hazardous energy, while servicing machinery, equipment, or systems.
NOTE: In some incidents it is likely that the equipment being worked on and the personnel doing the work may fall under two (2) seperate managers. In this case, BOTH Managers shall be equally responsible for meeting these requirements and the Plant Manager will appoint one of the managers responsible for the written report.
Promptly but not later than 24 hours following the incident, the Department Manager will initiate an incident investigation and notify each employee who was, or could reasonably have been, affected by the incident.
The Department Manager will shall ensure that the incident investigation is conducted by at least one employee who has the knowledge of, and experience in, the employer’s lockout/tags-plus program and procedures, and in investigating and analyzing incidents involving the release of hazardous energy. The employer may also use additional individuals to participate in investigating the incident.
The Department Manager shall ensure that the individual(s) conducting the investigation prepare(s) a written report of the investigation that includes:
- The date and time of the incident;
- The date and time the incident investigation began;
- Location of the incident;
- A description of the incident;
- The factors that contributed to the incident;
- A copy of any lockout/tags-plus log that was current at the time of the incident; and
- Any corrective actions that need to be taken as a result of the incident.
The Department Manager shall review the written incident report with each employee whose job tasks are relevant to the incident investigation findings, including contract employees when applicable.
The Department Manager shall ensure that the incident investigation and written report are completed and all corrective actions implemented within 30 days following the incident.
If the management team (Plant Manager’s direct satff) demonstrates that it is infeasible to implement all of the corrective actions within 30 days, the Plant manager shall prepare a written abatement plan that contains an explanation of the circumstances causing the delay, a proposed timetable for the abatement, and a summary of the steps the employer is taking in the interim to protect employees from hazardous energy while servicing machinery, equipment, or systems.
Program audits
The Department Manager shall ensure that an audit of the lockout/tags-plus program and procedures currently in use is conducted at least annually to ensure that the procedures are being followed and to correct any deficiencies.
The Department Manager will ensure that the audit is performed by:
- An authorized employee other than the one(s) currently using the energy-control procedure being reviewed; or
- Individuals other than an authorized employee who are knowledgeable about the lockout/tags-plus program and procedures and the machinery, equipment, or systems being audited.
The Department Manager will ensure that the audit includes the following:
- A review of the written lockout/tags-plus program and procedures;
- A review of the current lockout/tags-plus log;
- Verification of the accuracy of the lockout/tags-plus log;
- A review of LOTO incident reports since the last audit;
- A review was conducted between the auditor and authorized employees regarding the authorized employees’ responsibilities under the lockout systems being audited; and
- A review was conducted between the auditor and affected and authorized employees regarding their responsibilities under the tags-plus systems being audited.
The Department Manager will ensure that, within 15 days after completion of the audit, the individual(s) who conducted the audit prepare and deliver to the employer a written audit report that includes at least:
- The date of the audit;
- The identity of the individual(s) who performed the audit;
- The identity of the procedure and machinery, equipment, or system that were audited;
- The findings of the program audit and recommendations for correcting deviations or deficiencies identified during the audit;
- Any incident investigation reports since the previous audit; and
- Descriptions of corrective actions the employer has taken in response to the findings and recommendations of any incident investigation reports prepared since the previous audit.
Department Manager shall promptly communicate the findings and recommendations in the written audit report to each employee having a job task that may be affected by such findings and recommendations.
The Department Manager shall correct the deviations or inadequacies in the lockout/tags-plus program within 15 days after receiving the written audit report.
For those curious as to the source of these “suggestions” you can Click Here.
Hint: Those reading this and they are employed at a Shipyard… these are NOT suggestions!