Page 42 - Occupational Health & Safety, November/December 2019

LOCKOUT/TAGOUT
tive, understandable, and comprehensive is to collaborate across departments. Including the perspectives of safety mangers, maintenance personnel, operations staff, electrical and engineer- ing departments, and human resources will prevent complica- tions down the line by catching blind spots and roadblocks, and facilitating buy-in.
Procedures. A LOTO program should include written proce- dures specific to each piece of equipment or type of equipment. Even simple, single energy source equipment can pose a hazard, so it’s important to develop instructions for both simple processes and complex situations such as multiple energy sources and/or multiple crews and locations.
As for what to include, instructions should cover where and how to de-energize the energy load; how to release hazardous stored energy (discharging capacitors, for example); and how to verify that the equipment is de-energized and cannot restart while in the locked-out condition. An outline of these steps would gener- ally include:
■ Providing verbal notification of intentions to all affect- ed employees, adding signage and barricading the area where appropriate.
■ Shutting down a machine and/or equipment using standard stopping instructions.
■ Referring to pictures and steps to isolate all energy sources.
■ Securing each energy source with a lockout device. If equip- ment design does not provide accessibility for a lockout device, then additional preventative measures (such as removing a fuse) should be used in addition to tagout warnings.
■ Releasing all residual and stored energy.
■ Verifying that all energy sources have been de-energized.
■ Notifying all affected personnel that normal operations
can resume.
Training. NFPA 70E requires three types of employees to be trained for an effective LOTO program, authorized, affected and other employees.
Authorized employees are those responsible for locking and tagging out equipment. These employees must be able to demon- strate competence in executing the specific LOTO procedures they will be using. Their training should also identify all the hazardous energy sources present in the facility as well as the methods used for isolating and controlling them.
Affected employees are not directly responsible for LOTO pro- cedures, though they do interact with the affected equipment and must understand the general process (definitions, responsibili- ties, devices) and why it is important to avoid starting up or using equipment during these procedures.
Any other employees who work in an area where energy control procedures will be utilized (such as office or warehouse personnel) also need to be aware of the importance of the LOTO program.
Devices. Devices are only effective as part of a company’s over- all approach to training, procedures, and review. The devices used for lockout should be robust, unique, and easily identifiable. When in use, a warning tag that also identifies who installed the device should also be securely attached. LOTO devices should be able to be installed without tools, and the keys for locks must remain with the individual(s) who installed the devices to ensure that the power source cannot be re-activated by anyone else.
Review. The final element of inspection and review ensures a lockout program’s effectiveness. Annual program documenta- tion and procedure review is needed due to employee turnover, and to ensure that a process doesn’t become too comfortable and prone to error.
Another important element of review is continually assessing your safety program against industry best practices regarding the most current technology available. Understanding where safety tools used in your program fall within the Hierarchy of Risk Con- trols is one way of measuring program effectiveness.
The hierarchy ranks risk control measures from most to least effective:
■ Elimination physically removes the hazard.
■ Substitution replaces the hazard with something non-haz- ardous or minimizes the hazard.
■ Engineering controls prevent access or act as a barrier be- tween personnel and hazards.
■ Administrative controls attempt to change the way people work through training, procedure, policy, and signage.
■ Personal protective equipment can be effective in tandem with administrative controls but does not eliminate the hazard.
Elimination and substitution remove or reduce the hazard it- self; the lower three tiers only reduce exposure to the risk. These lower tiers of the hierarchy may often be easier to implement but are not necessarily the most cost-effective for the long-term.
LOTO is still mainly a manual process that depends largely on administrative controls (procedures and training) for the proper implementation of tools and devices that fall within any other level. The effectiveness of administrative controls depends on the mitigation potential of the controls and how consistently they are followed.
38 Occupational Health & Safety | NOVEMBER/DECEMBER 2019
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