Lockout is a life-critical program/process/procedure(s). Our efforts to VERIFY that the program/process/procedures meet our needs is a CRITICAL path in the LOTO process. OSHA recognized this when it promulgated its Control of Hazardous Energy standard (1910.147). Specifically, 1910.147(c)(6) “Periodic Inspections” requires the employer to verify the program/procedures and that the employees can properly apply them to their maintenance and servicing tasks. If all goes well, this activity should be 10 minutes for simple LOTOs. The “inspector” does the following:
- Have the authorized employee OBATIN the machine-specific procedure. NOTE: If there is NOT a machine-specific procedure due to the “complexity” of what needs to be isolated, then this “inspection” will take longer and be a bit more complicated, but even MORE CRITICAL that we verify this authorized employee can
- IDENTIFY the Types of Hazardous Energy,
- the MAGNITUDE of each source of energy,
- how each type of energy will be ISOLATED and
- the means/methods by which they will VERIFY THAT THE ENERGY SOURCES ARE AT A ZERO ENERGY STATE (ZES).
- Once the procedure has been obtained, have the authorized employee LOCATE each isolation device as stated. This in itself can be a challenge when the procedure is not well written; hence, an opportunity to improve the procedure!
- When the employee locates EACH isolation device, they should DEMONSTRATE HOW to utilize the isolation device, as well as HOW to apply the lockout device to the isolation device. This may sound simple to some, but trust me – you may be surprised at how challenging this can be for those who claim they lock out all the time but can not demonstrate how to use the energy isolation or lockout device.
- Once they have demonstrated how to use the isolation and lockout device(s), they then DEMONSTRATE how to achieve a ZES for each type of energy that was isolated AND how they go about VERIFYING that a ZES has been obtained.
When the authorized employees can DEMONSTRATE, they can do ALL FOUR (4) of these tasks as required by the procedure they pass their periodic inspection.
I like to find work already being done and audit the LOTO for that job, as this verifies not only that the employees know HOW to implement the procedure but also that the procedure(s) are being utilized/implemented when required. However, we will have some authorized employees who we do not find working during their normal course of work, and we will have to do a “mock” inspection to meet the annual periodic inspection needs for ALL authorized employees. When faced with this situation, the 4-step process above is how I required those inspections to be done.
Lastly, I believe that every AUTHORIZED Employee MUST participate in a periodic inspection on an annual basis. We also did LOTO training annually, but we believe that they should be able to DEMONSTRATE they fully understood their training and the machine-specific procedures. None of my plants ever completed 100% of our periodic inspections with a score of 100% – we always found procedural errors (usually caused by a change in the plant) or personnel who could not locate or properly utilize the energy isolation and/or lockout device(s). Our goal was always 100%, but never in my 15 years as a safety manager did we every achieve that goal. But this was how we CONTINUOUSLY IMPROVED.