Page 64 - OHS, July/August 2021

TRAINING: LOCKOUT/TAGOUT
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Lockout/tagout is a great example of traditional workplace safety in action: identify a hazard, put a procedure in place and train workers to follow that procedure in order to avoid exposure to the hazard. It’s a nice, clean solution and one
that’s proven to be incredibly effective.
There’s just one catch—it only works when all employees
follow the procedure to the letter. However, you can design the most elegant, precise procedure in the world and workers will still fail to follow it for all sorts of reasons. In rare instances, procedures like LOTO are overlooked due to blatant disregard. Much more frequently, the rules are unintentionally violated. People momentarily forget because they’re tired, they’ve become complacent or they’re in a rush.
Lockout/tagout rules aren’t new, and the standards that govern the control of hazardous energy have remained fairly consistent for a long while now. But for the last two decades— as long as I’ve worked in the safety industry—the issue has been among OSHA’s top 10 most cited violations. So, in addition to employees following procedures to the letter, maybe the letters of the procedure also need to follow employee behavior. The rules governing lockout/tagout are sound, and there’s no need to re-invent the wheel. But something more is required. I’d like to propose that supervisors are the key to reliably governing the lockout/tagout.
It would be great if you could create procedures, training plans and systems that would account for all of the unique combinations of equipment, people, human factors and situations that can arise on any given day without permanently locking down their entire plant. However, unless you can squeeze an extra dozen hours into each day, that’s not a realistic option.
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Instead, safety managers need to supplement their standard program with dynamic support on the ground to fill the inevitable variability gaps—which means they need to empower supervisors to deal with the LOTO problems that creep in at the margins.
Shift supervisors and other frontline leaders are such a useful feature of a strong lockout/tagout program option because they can act as a bridge between employees and organizational safety systems. On the system side, supervisors can be the company weathervane, indicating which way the safety winds are blowing. On the individual side, supervisors can offer key support to employees who need it, when they need it.
Supervisors and Systemic Rushing
Lockout/tagout violations are typically viewed as a personal contravention of a system that was built to run just fine—an individual throwing a wrench in the safety gears, so to speak. But in many cases, what looks like an individual rushing through a task and skipping a few safety steps is actually a function of organizational priorities.
Over the last three decades, the organizational sciences—the collection of disciplines and subfields that study how large groups of people interact and behave in structured environments—have conclusively determined that workers’ actions are a reflection of the system in which they occur. When people act in certain ways, there’s a reason for it. If people aren’t following the LOTO procedures, it’s worth taking a close look for any structural reasons that might be contributing factors. Often, it comes down to a handful of issues: inadequate training, institutional pressures and a failure to mitigate complacency.
In the case of inadequate training, there’s not much I can tell
60 Occupational Health & Safety | JULY/AUGUST 2021
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