Tired of endless meetings about budget and cost cutting? Had enough with your crew not following through on safety?
Want in on a little secret on how to improve your bottom line and improve facility safety?
Go ahead, grab a seat and let's talk about a few lockout/tagout stats.
From October 2015 to September 2016, there were 2,898 OSHA citations and almost $13 million in penalties for insufficient or incorrect lockout tagout (LOTO) programs across all industries. In fact, LOTO (CFR 1910.147) ranked #5 on OSHA’s Top 10 Most Frequently Cited Standards!
Let’s get back to that $13 million in fines. Do you find yourself wondering what mistakes could have been made to account for that many citations? Are you second guessing your own energy control program? It's often the smaller operations that aren't using LOTO properly! Right down to the carpenter not using a plug lockout on a radial arm saw.
Nobody wants to think there a kink in their chain. But if there was, wouldn’t it be great to fix it before you get slapped with a big fine or someone gets hurt?
Here’s some of the biggest LOTO violations that are found year after year:
- Employer fails to have an energy control program
- Employer fails to train employees on proper procedures
- Employer fails to periodically inspect energy control procedures
Here’s what OSHA wants from you:
Develop an energy control program that has clear, written procedures, employee LOTO training and periodic inspections to protect any workers anytime. Implement that plan and enforce it. Sounds simple enough, but it doesn’t end there.
Here are the specific requirements for inspections included in CFR 1910.147
- Periodic inspections will include a review of lockout, between the inspector and the authorized employee, of the employee’s responsibilities under the energy control procedure being inspected.
- If tagout is being used, there will be a review between the inspector and each authorized and affected employee, of the employee’s responsibilities under that energy control program.
Training requirements include: (Spoiler alert: Here comes the “fun” regulation stuff!)
Employer shall provide training to employees and make sure that the purpose and function of the energy control program is understood by employees. Be certain that employees acquire the knowledge and skills required for safe application, usage and removal of energy controls. Employer shall certify employee training and keep documentation of certification, including employee name and dates of training.
That's not all! Check these requirements out:
- Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, type and magnitude of energy available in the workplace, and the means necessary for isolation and control
- Each affected employee must be instructed in the purpose and use of energy control procedures
- All other employees who are in the vicinity of area where energy control procedures may be used must be instructed about the procedures and any prohibitions relating to attempts to restart or re-energize machines (or equipment) that are locked out or tagged out.
If there is a tagout system, employees must be trained in these areas:
- Tags are warning devices placed on energy isolating devices and do not provide the physical restraint that a lock does
- Tags should not be removed without authorization of the authorized person who put it on and should NEVER be bypassed, ignored or otherwise defeated
- Tags must be legible and easily understood by all authorized personnel, affected employees and all employees whose work operations are or may be in the area
- Tags must be made of materials that will not deteriorate or be damaged in the environment
- Tags may give the sense of false security and must be explained that they are only part of an overall energy control system
- Tags must be securely attached to energy isolating device so that cannot be removed or detached during use
Employee retraining for Lockout Tagout:
- Employees shall be retrained anytime there is a change in job assignments, change in machines, equipment or processes that could present a new hazard, or a change in an energy control procedure.
- Retraining must occur anytime an employer has reason to believe the employee does not possess the knowledge of how to use energy control procedure.
- Retraining is also used to re-evaluate employee’s skill and knowledge of energy control methods and introduce new or revised control methods.
When it comes to LOTO removal, each device must be removed by the employee who applied it.
In Case of an Emergency...
...And if authorized person isn’t available to remove it, the employer is now responsible for all attempts to ensure that the applier is not at the facility.
This should include attempts to reach authorized employee and let them know that device has been removed and make sure all affected employees know the device has been removed before they start work.
What if the worker who applied the device, came back to work and wasn’t told the equipment was now energized? It doesn’t have to be a monumental fail to cause someone to get hurt. Overlooking simple procedures is often what leads to injury.
There is a lockout or tagout product for every situation, here are just a few:
OSHA Danger Steering Wheel Message Cover: Do Not Operate or Move Vehicle: Reinforced vinyl cover has digital printed warning legend and message and fits over standard steering wheels. Ideal when a vehicle is disabled or being worked on!
Grip Tight™ Circuit Breaker Lockout: Effectively lock out circuit breakers, plugs and wall switches. Device has narrow profile that allows side by side breaker lockout and made of durable powder coated steel and reinforced polymer that can stand up to harsh conditions.
Oversized Plug and Hoist Control Cover: Effectively lock out odd size and large electrical connectors and hoist controls with a device that offers broad solutions. Flexible and durable rip-stop nylon bag fits easily in safety tool boxes.
Are you still there? You didn’t leave, did you?
Listen, not following these guidelines can end up in serious injury, amputation or death. It’s just not something to play around with. And even if you have made sure the process is in place, make sure your people are on board, as well as any outside personnel. It’s the employer’s duty to inform subcontractors or outside people about the specific LOTO procedures that are being used.
When you fail to do all this, it’s just like the old saying, “the left hand doesn’t know what the right hand is doing”.
Let’s be honest, the work you do is tough enough, don’t make it harder. Just do the right thing upfront and you can make sure your people get to clock out safely. Save a couple bucks in fines in the process. And maybe your boss will give you that raise you’ve been wondering about.
Safety: It’s Your Life, It’s Our Business