Page 72 - OHS, July/August 2021

TRAINING: LOCKOUT/TAGOUT
Step 4: Standardize Training Materials and Organize 1910.147(c)(5)(ii)(B) requires both lockout and tagout devices to be standardized within a facility. ThThis includes shape, size or color for locks, print and format for tags. Standardization is important in safety procedures because it makes dealing with known hazards routine and easier for employees to recognize on sight. Applying the same principles of standardization and keeping training materials organized can also help strengthen LOTO safety in your facility.
First, clearly identify training materials for authorized, affected and “other” employees to ensure that the right information is getting to the right people. Use standardized labels, color-coded binders or dividers to make it easy for employees to quickly navigate to the information they need.
Next, make sure training information is not only accessible but digestible. Well-organized materials allow you to provide much more information for employees in a wide variety of formats. Training materials that range from whitepapers and your full company policy for controlling hazardous energy, to short OSHA handouts or links to videos online, accommodate a wider variety of learning styles. The more resources available to your team, the more knowledgeable they become, increasing LOTO safety in your facility.
Step 5: Streamline Training Records
1910.147(c)(7)(iv) requires employers to certify that training has been completing and is being kept up to date with certification records that contain each employee’s name and the dates of their training. Whether you store LOTO training records physically or digitally, it’s a good idea to standardize a system for separating records for authorized, affected and “other” employees.
Keeping your records streamlined and organized will help save time during OSHA inspections as well as in-house inspections and/or retraining. If you’re storing records physically, ensure that you use heavy-duty binders, sheet protectors and plastic dividers that will not degrade in an industrial setting.
Step 6: Reinforce Best Practices and Training Basics
Provide visual tools to help your team stay vigilant. For example, posters, safety signs, labels and tags that reinforce best practices, training basics and protocols that are unique to your facility.
Every authorized, affected and “other” employee working with machinery/equipment that stores hazardous energy should know the six steps of LOTO safety by heart.
Safety posters featuring the six steps of LOTO safety and other LOTO training procedures specific to your facility are a great way to help workers commit important information to long-term memory and/or review daily as needed.
Step 7: Conduct Periodic LOTO Inspections
LOTO inspections are covered under OSHA 1910.147(c)(6) and require that an authorized person inspects the facility’s total energy control/lockout tagout procedures at least once a year. However, it’s considered best practices to conduct an inspection in the following instances: 1) after retraining has occurred or 2) if you suspect procedures are not being followed.
During lockout/tagout inspections, OSHA requires the following:
■ ■ ■
The best way to help your team safely work with stored energy is to ensure you have a strong lockout/tagout (LOTO) training program for controlling hazardous energy.
All procedures for each machine must be inspected Employees cannot inspect themselves
All authorized and affected employees must be reviewed
(group reviews work, OSHA does not require individual reviews) ■ The employer must certify inspections have been done
■ Certification must identify the machine/equipment and
include the procedure, the date, the employees involved and the person who performed the inspection
Step 8: Facilitate (and Record) Retraining as Needed
1910.147(c)(7)(iii) covers retraining employees in LOTO safety. At minimum, retraining must occur when: 1) there is a change in job assignments for authorized or affected employees, 2) a change in machines, equipment or processes present a new hazard or 3) there is a change in energy control procedures.
OSHA also mandates that additional retraining must be given to employees “whenever the employer has reason to believe that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.” This can happen after a routine inspection or any time the employer has any reason to question the employee’s proficiency.
Employers must certify LOTO retraining in the same manner as regular LOTO training (i.e. including the employee’s name and the dates of their training). Use the same record management procedures for training and retraining certification to increase standardization and efficiency.
Benefits of Strengthening LOTO Training
Whether you’re building your LOTO training program from scratch or updating your current program, a few key fundamentals make all the difference. Identify employees to ensure the right people get the right information. Document, standardize and organize the specific lockout/tagout procedures in your facility, certification records, inspection records and training materials. Reinforce best practices and conduct regular inspections to keep everything on track.
JoAnn Mrgich is a technical & content writer for Avery Industrial. Colwin Chan is a Marketing Director for Avery Industrial.
68 Occupational Health & Safety | JULY/AUGUST 2021
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