Page 78 - OHS, July/August 2020

TRAINING: LOCKOUT/TAGOUT
ers have a functioning lockout program that meets all or most com- pliance requirements. Approximately 60 percent of U.S. companies have addressed the major elements of the lockout standard, but in a limited manner. Concerningly, roughly 30 percent of companies currently have no significant lockout program in place.
As organizations look to implement effective lockout programs, careful consideration must be given to the policies and procedures of lockout activities: an important element being procedures re- lated to shift changes.
How Shift Changes Create Gaps in
Lockout Safety & Compliance
One of the situations where companies and employees are most vulnerable to the hazards of improper or inadequate lockout is dur- ing a shift change.
Gaps in the effort to control hazardous energy can occur when the first shift of workers transfer lockout responsibility on to the second shift (and in some cases, the second on to the third).
In order to address this issue, OSHA standard 1910.147(f)(4)4 states the following:
“Specific procedures shall be utilized during shift or per- sonnel changes to ensure the continuity of lockout or tagout protection, including provision for the orderly transfer of lockout or tagout device protection between off-going and on- coming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equip- ment, or the release of stored energy.”
When it comes to shift changes, employers have four options
for meeting the OSHA requirements:
1. Authorized employees can leave their personal lockout de-
vices in place until the job is completed.
2. On-coming employees may apply their personal lockout
devices before the off-going employees remove their personal lockout devices.
3. On-coming employees start the lockout process from scratch by applying and releasing lockout for the entire time of servicing. The equipment is first returned to operational status (with guards in place), and then employees administer lockout procedures on the equipment.
72 Occupational Health & Safety | JULY/AUGUST 2020
4. The company may incorporate and utilize continuity devices into their lockout/tagout program. These devices are often referred to as “transfer locks.”
While all four options are sufficient in meeting the OSHA re- quirements, the use of a transfer lock system has proven to be one of the most effective in ensuring the continuity of protection be- tween shifts.
Incorporating a Transfer Lock System
into Your Lockout Program
Workplaces that frequently require a transfer of lockout respon- sibility should consider the use of transfer locks. The intention of continuity devices is to ensure that all employees are protected dur- ing shift and personnel changes.
The basic procedures for using a transfer lock are:
1. An authorized employee places a transfer lock onto the hasp, lockbox or other energy isolation device.
2. Employees from the first shift place their own individual pad- locks onto the same energy isolation device. If an energy isolating device cannot accept multiple locks, a hasp or group lockout box may be used.
3. Employees from the first shift remove their individual pad- locks before going home at the end of the day.
4. Employees from the second shift add their individual pad- locks to the energy isolation device before working on the hazard- ous energy source.
5. This process continues until the work is completed and em- ployees from the last shift remove their individual padlocks.
6. The transfer lock should be the last to be removed, once the job is complete.
It’s important to note that employees from the on-coming shift must verify for themselves that the de-energization and isolation of hazardous energy has been completed. Employees should never depend upon the actions of the off-going shift, nor should they as- sume that the hazardous energy has already been isolated.
It is also recommended that the transfer locks are a differ- ent color or type than the employees’ individual padlocks. This enables workers to quickly and easily identify the presence of a continuity device.
Because there are many steps involved, it’s recommended that companies designate individuals on each shift to be responsible for managing the lockout. This “primary authorized employee” is usually the shift supervisor or department manager and is respon- sible for ensuring shift change continuity. He or she is in charge of administering the shift transfer devices, managing the key(s) and coordinating authorized employee changes for affected workforc- es. They must also be familiar with their company’s lockout/tagout policies and procedures.
If the use of continuity devices has been chosen as the method for meeting shift change compliance, the written program should include the following information:
■ The identified colors of continuity device locks.
■ The steps and procedures for implementing lockouts that involve continuity devices.
■ The established methods for involving contractors in shift change lockouts.
■ The necessary training that employees must complete on the www.ohsonline.com
J R Price/Shutterstock.com