Page 47 - Occupational Health & Safety, March 2018

LOCKOUT/TAGOUT
Lockout Leadership as a Path to Advancing the Practice
BY TODD GROVER
www.ohsonline.com
MARCH 2018 | Occupational Health & Safety 41
Since the inception of the practice of lockout/ tagout dating back to the first ANSI stan- dard on the subject issued in 1982, control- ling the release of hazardous energy has ad- dressed a need while also created challenges. Without securing machinery to prevent sudden startup, work- ers focused on the task at hand have little chance to react if their actions or the decisions of others cause dangerous machine activity to occur. The challenges are to engage those workers in understanding their exposure, consistently taking the right precautions, and watching out for others who could be hurt by their actions.
The OSHA Lockout regulation, particularly as it is laid out in detail found in CPL 0200147 Enforcement Policies and Inspection Procedures, creates obliga- tions for employers to follow. Yet, 29 CFR 1910.147 violations consistently rank among OSHA’s most frequently issued citations every year. Again in 2017, OSHA ranked lockout as number 5 in the Top 10, with the following areas being cited most frequently:
■ 1910.147(c)(4)(i)—Failure to provide Energy Control Procedures
■ 1910.147(c)(1)—Failure to have or follow the required Energy Control Program
■ 1910.147(c)(6)(i)—Failure to perform Periodic Inspections of energy control procedures
■ 1910.147(c)(7)(i)—Failure to Train or properly Communicate lockout skills and requirements
■ 1910.147(c)(7)(i)(A)—Failure to prepare work- ers to recognize applicable hazardous energy sources
Madness is artfully described as continuing to do the same thing but expecting to get different re- sults. So unless we advance our lockout practices, we can expect to see lockout again in 2018 and beyond
ranked as number 4 or 5 in the Top 10. Because all the rules, engineering methods, lockout devices, and various training programs already exist but are falling short of effectively solving the problems, enhancing engagement at all levels of employment is a viable so- lution to drive better practices going forward.
Using Safety Champions
A Safety Champion Program is not a new concept. The companies that use Safety Champions effectively send a clear message from management to workers; “We believe that it is important for you to go home healthy at the end of the day. To assure this happens, we are going to make safety a part of everything we do and get everyone involved in making it happen.” These programs are often very broad in scope and focus overall on better preparing workers to succeed, empowering change to address hazards, and involving personnel at all levels to improve the safety and pro- ductivity of the workplace through their participation.
A leadership program can be the connection be- tween a well-done administrative program and the re- ality of how the work is performed on the plant floor. Lockout leadership is based on a mentoring approach that succeeds because it establishes these critical protective practices as the normal way jobs are per- formed, rather than an extra and sometimes optional safety step. The program looks like this:
The company’s written lockout program should be designed as a guide that describes what good lock- out practices are intended to look like specific to the facility. Responsibilities at each practical level are well defined and lockout leadership is added as a role. By turning the program into a user-friendly tool, it can be used as the basis for training workers rather than the common focus of OSHA regulatory requirements and misapplied exceptions. It is much more effective to share with workers the ways and means the company has decided to do things, rather than let impersonal government regulations drive critical behaviors. Of course, the user-friendly program takes into consider- ation all the regulatory requirements and has worked them into the methods shared during training and practical applications.
Classroom lockout training for authorized per- sonnel, often provided by safety and health personnel, focuses on company expectations from the written program; roles and responsibilities; demonstrations of practices common to all, such as lock color schemes and assignments; and tagging methods. This is also the time to explain the role of lockout leadership in supporting the use of energy isolation procedures,
THE MASTER LOCK COMPANY