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Unravelling Common Lockout Tagout Pitfalls

dateJuly 21, 2020

One of the key benefits of the Lockout Tagout system is that the overall process is not only an elementary step to be undertaken, but a complete life savior and life protector. The system also helps reduce the amount of man hours that can potentially be lost and reduce production downtime - all factors that will result in improved business performance.

This procedure protects workers from the risks posed by live machinery or electricity. These hazards can come from a whole range of energy sources including electricity, pneumatics, steam, gas and liquids to name a few.

OSHA 1910.147 outlines the requirements for the control of hazardous energy (Lockout Tagout) with specifics on written programs, energy control procedures, training, and periodic inspections. Unfortunately, as with many OSHA requirements, they inform you “what” to do, but not “how” to do it, and leave this part up to the employer. The challenge for many employers is the lack of knowledge or experience to effectively implement the OSHA lockout guidelines so that they are effective and meaningful.

The Top Six Lockout Tagout Challenges are listed below:

These are the most common problems with lockout tagout which may become the reasons of unexpected accident in the workplace area.

1 - Lack of Awareness

2 - Lack of Specific Procedures

3 - Inappropriate Selection and Procurement of Devices

4 - No timely Reviews and Audits

5 - Insufficient Training

6 - Not able to maintain a Sustainable LOTO System

Let us discuss all these challenges in detail:

1. Lack of Awareness

For developing a culture that supports workplace safety, it is essential that the top-management has absolute knowledge regarding the subject. Lack of awareness and absence of LOTO system leads to eventualities and fatalities. Even with the recurrence of repeated incidences, the workers and the management are not sure that it is due to the absence of proper LOTO system in place.

Therefore, it becomes the responsibility of the top-management to understand the importance of Lockout Tagout, and follow it diligently, only then it will percolate to down the line managers and supervisors. Workers who are handling the hazardous energies are not aware of the magnitude, and hazards present in the equipment, therefore, they do not take the LOTO process seriously.

So, the level of awareness must be enhanced at all levels.

2. Lack of Specific Procedures

Time and again, we have observed that one of the biggest challenges at the workplaces is lack of procedures. For LOTO Implementation most of the organizations just procure the Lockout Tagout devices, provide generic training and assume that LOTO has been taken care of at their facilities. But overall and specific procedures are integral to support systematic implementation of Lockout Tagout standard, also they are mandatory as per [29 CFR 1910.147(c)(1)]; [29 CFR 1910.147(c)(4)(i)]; and [29 CFR 1910.147(c)(4)(ii)].

Employers must establish a program that includes energy control procedures and employee training. Specific procedures should be written for each piece of equipment or process that identify all energy sources & energy isolation devices along with the specific steps for application and removal of Padlocks and Tags. The procedure becomes the checklist to assure that all energy sources are controlled before servicing and maintenance starts.

3. Inappropriate Selection and Procurement of Devices

It has been observed that many a times organizations fail to understand the importance of Lockout Tagout by simply procuring general Lockout Tagout devices and not focusing on getting the specific, duly customized, right devices.

Survey your premises and asses the right kind of isolation devices required for your machines, because different applications need specific customized lockout tagout devices for fool-proof isolation. Another reason for the failure of LOTO is the purchase of the cheap or L-1 products available in the market, by the purchase department. Due to financial constraint and general specifications from the user department, they buy general LOTO devices from local vendors, without knowing its repercussions.  

Most of the times, these devices are bought, just to meet the compliance formalities, assuming that these basic LOTO kits will make them LOTO compliant. But they forget, that LOTO is not just about product, it is a complete project that needs to be implemented.

Serious incidences take place in the industries during servicing, due to release of hazardous energies- only because of inadequate Lockout Tagout equipment available at the sites.  Therefore, it becomes the management’s responsibility to be careful while selecting the right Lockout Tagout devices.

Industries can take help from professionals who are subject matter experts in surveys, and have in-depth knowledge of the latest innovative solutions for critical isolations.

4. No timely Reviews and Audits

OSHA requires an annual audit of each procedure and a review of the audit findings with each authorized employee where lockout is used, and each authorized and affected employee where only tagout is used. The audit should determine if all energy sources have been identified, if employees understand which energy source is harmful and which is not (such as water pipes and low voltage), and if the energy control procedures are understood and followed.

Reports and evidences of accidents during servicing demonstrate the inefficiency in annual audits and reviews. When timely audits and inspections are not performed, deficits of the current LOTO program are not examined or detected, the result is accident and mishap, sooner or later.

Timely audits and reviews bridge the gap between lackings and shortcomings of the procedures which help the company stay compliant and confident.

5. Insufficient Training

Lockout Tagout is internationally recognized as a Top risk to organizations and the main reason behind this is inadequate and insufficient training of the workforce that carry out energy isolation tasks.

To achieve the target of zero-accident it is imperative that high-impact and interactive training must be imparted to all employees. It is the Top-management’s responsibility to build a culture of timely training of their employees in order to keep the work practices and safety standards updated and to absorb the best practices in industrial safety.

The organizations should adopt a tiered training concept for all levels of training, ranging from tier 1 to tier 4.

  • Generic Training - It is a part of Tier ‘1’ section of the training which includes all the employees of the company, be it the senior manager, the authorized, affected or general employee of the company whether or not directly related to the servicing and maintenance of equipment.
  • Intensive Training - This level of training is included in the Tier ‘2’ and tier ‘3’ section of the LOTO training procedure. In this level of training, only the authorized employees are included for the purpose of training.
  • Mastery and Excellence Level - This level of training includes the final tier system- the tier ‘4’ where the LOTO leaders and LOTO masters are trained furthermore to the excellence level and they become the advocates of the safe energy isolation.

With proper Trainings LOTO challenges can be addressed to a great level.

6. Not able to maintain a Sustainable LOTO System

For a sustainable and robust LOTO system, it is highly proposed by LOTO experts to take a continuous improvement approach to your lockout program. Companies must consistently review their LOTO program for developing a safety culture that proactively discourses lockout tagout. Focusing on a dynamic LOTO system helps to maintain a world-class program, instead of starting from scratch each year and reacting only when you realize you went wrong.

If the cost of sustainability bothers you by any chance, then think about the costs of re-creating your lockout tagout program each year - when you could easily maintain your program without even spending much amount on the process. 

Therefore, having a sustainable Lockout Tagout program with continuous improvements, helps you stay one step ahead saving time, energy, money and also eliminating future risks.

Implementing proper and effective lockout program can be challenging, but once implemented, safety, time and quality can be improved. It all starts with assigning a lockout champion who has the knowledge and authority, and requires the cooperation of multiple departments and levels of workforce. Implementation also takes time and investment and may require the services of third parties. It can’t all be accomplished at once, so prioritize your needs, assign budgets, and take on one task at a time. To be precise, choose an expert, authorized, experienced and renowned Lockout Tagout safety professional, who can hand - hold and lead you to the fair path.

E-Square Alliance, your No. 1 Energy Isolation partner and guide, has been working tirelessly on the systematic approach to safe energy isolation with the industries world-wide and has been receiving an overwhelming response. We are committed towards preparing employers and employees to overcome their Lockout Tagout challenges. So, developing a dynamic LOTO System can be challenging but with experts, it becomes simple and enjoyable.

E-Square Compliance and Education Division
About the Author

E-Square Compliance and Education Division

A team of safety professionals and educators united to enhance workplace safety with essential Lockout Tagout knowledge. We offer expertise to foster safety compliance and effective LOTO protocols across industries.

E-Square Blog: Expert Analysis and Best Practices for Isolation Safety

The E-Square blog features advice, information and support on everything related to Lockout Tagout, including best practices, industry news, latest innovations and regulatory updates.

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