Page 36 - Occupational Health & Safety, December 2017
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LOCKOUT/TAGOUT
Controlling Hazardous Energy with Lockout/Tagout— Common Challenges and Best Practices
We have found that only about 10 percent of companies run effective lockout programs. In fact, we have observed that
up to three-out-of-ten employers have no lockout program at all. BY TODD GROVER
Workers began to specialize in operat- ing and maintaining machinery in the Industrial Revolution. And quickly, consequences occurred: Those workers were increasingly injured or killed while servicing this equipment. This spurred improvement in the design of machinery to shield people from the dangerous work they performed.
The early efforts of the National Safety Council and similar organizations to raise awareness of the impor- tance of machine guarding reduced the rate of acci- dents that were suffered while machinery was operat- ing. But when these machine guards were removed to repair or service that equipment, a disturbingly high number of incidents continued to take place as equip- ment suddenly started up or released dangerous flows of energy, taking operators and other personnel by surprise. The American National Standards Institute (ANSI) began looking at these causes of injuries and fatalities in the 1970s and published its first guidance on controlling hazardous energy with the practice of lockout or tagout in 1982. The ANSI Z244.1 lockout standard became the inspiration for the OSHA regu- lation of 1989 requiring employers to put procedures in place to protect their workers by fully isolating ma- chinery from the energy sources that drive them.
Despite the requirements of OSHA 29 CFR 1910.147 and other related federal and state regula- tions, incidents continue to occur at a pace that makes violations of the lockout/tagout requirements peren- nially one of OSHA’s most frequently cited regula- tions, as well as one of the costliest.
What Makes Lockout Compliance So Difficult?
Twenty-eight years after the OSHA lockout regula- tion went into effect, the law remains one of the most challenging for employers to successfully facilitate in their workplaces. From our years of field experience at facilities in many industries, we at The Master Lock Company have found that only about 10 percent of companies run effective lockout programs – defined as meeting or exceeding compliance requirements with lockout being practiced routinely each time it is indicated by the hazards of the tasks being performed. In fact, we have observed that up to three-out-of-ten employers have no lockout program at all.
The other six-out-of-ten companies find them-
selves somewhere in between. They may be in the initial stages of encouraging their employees to ap- ply lockout when needed or improving the regularity of protecting themselves. Or they may have the goal of moving into the echelon of those top companies whose people routinely protect themselves when ser- vicing machinery. Any time a company can pursue proactive, continuous improvement on a controlled timeframe, rather than as a reaction to a crisis, it is substantially beneficial to their bottom line and sus- tained profitability.
It’s difficult for companies to routinely practice lockout because the OSHA regulation is very demand- ing and the sporadic nature of when lockout needs to be applied can cause significant logistical challenges. For instance, often only select authorized personnel re- ceive the training and other resources to use lockout to protect themselves. Yet the need to apply lockout comes up frequently. It can be complicated by time consider- ations, insufficient numbers of trained personnel with access to accurate procedures describing primary and residual energy control measures, as well as the lack of quick access to safety equipment used to secure energy isolation devices, such as switches and valves. When we combine those factors with the challenge that sometimes energy sources must remain on to perform certain tasks, the variables combine to create confusing and conflicting messages to those tasked to maintain equipment. As a result, many managers and their work- ers believe lockout can impede productivity.
For the latest in best practice guidance on the control of hazardous energy sources, the ANSI/ASSE Z244.1 (2016) standard was updated extensively and provides the latest methodology and technological practices in a highly usable format that explains how to improve the facilitation of lockout, tagout, and alternative methods to control hazardous energy sources. Z244.1 (2016) is a must read for anyone seeking to improve their practice of locking out energy-related hazards.
So, Where Should You Start?
A common challenge companies face when seeking to begin or improve the use of lockout to protect their workforce is where to start. From the emphasis pro- vided in Z244.1, the best way to begin is with a written plan of the lockout practices needed to achieve compli-
32 Occupational Health & Safety | DECEMBER 2017
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