August 21, 2020
Despite the simplicity, quick installation, low cost, and severe consequences of non-compliance, lockout-tagout is still considered troublesome and inconvenient. In 1995, Lockout Tagout was the number one most frequently violated standard in several industries, including food processing, textile mill products, paper products, and primary metals (Department of Labour). At present, it remains to be the number one most frequently violated citation in the manufacturing industry.
By all accounts, OSHA's lockout-tagout standard is not one of those "burdensome regulations" that employers complain about. According to the OSHA regulators, the 1989 rule mandating control of hazardous energy sources during service and maintenance is one of the most important they enforce.
Health and safety authorities levy the following standards and regulations that confirms that the application and implementation of Lockout Tagout is a crucial step and that considering it troublesome can be a mistake -
OSHA 29 CFR 1910.147 - Control of Hazardous Energy
It protects general industry workers performing servicing and/or maintenance on machines or equipment and who are exposed to the unexpected energization, startup, or release of hazardous energy.
OSHA 29 CFR 1910.333 - Electrical Safety
Regulation for safety-related work practices to be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized.
ANSI Z244.1-2003 - Lockout Tagout and Alternative Methods
A voluntary national consensus standard that represents several industry hazardous energy control best practices and promotes greater flexibility through the use of alternative methods based on risk assessments and application of the hazard control hierarchy.
Across all industries, OSHA cited employers for 4,728 lockout-tagout standard violations last year and issued more than $9 million in fines, making lockout-tagout one of the most expensive rules to violate.
Since every employee is burdened with targets and work commitments to be accomplished, their busy schedule sometimes makes even the simplest of the work look burdensome. Lockout Tagout is critical to the workers' safety and, therefore, cannot be considered burdensome at any cost.
How can a procedure that saves lives, cuts costs, improves productivity, provides moral support, and builds employee trust be burdensome?
Lockout Tagout protects the employees from future consequences of adverse events. Industries make a mistake of calling it burdensome because of -
Since we cannot see the promise of Lockout Tagout manifest instantly, we undermine its importance. It is the management's responsibility to understand the significance of proper energy isolation and educate every employee working on or around the machine about the subject. Clarify and communicate the reasons for the implementation of lockout tagout. Why is it being done? What makes it necessary? People need to understand the purpose of lockout tagout than simply being ordered to accept it. This aids employees in working with confidence, on account of more awareness of the subject, and being convinced about its usage.
This can be challenging for the company and its administration. Sometimes employees do not want to accept change. Their over-confidence makes them complacent as they find themselves working without any extra protection on a particular machine for years, with no accidents. Workers often have down-time pressures and find LOTO time taking and demanding. Consequently, they take short cuts and lapses occur. So, culture change and behavior-based safety should be focused on, and employees should be convinced both conceptually and emotionally that change is for their betterment. There has to be visible leadership that leads by example; only then change will be welcomed by one and all.
Again, the administration and the employer, in turn, are responsible for the safety of their employees and, therefore, are liable to provide proper and effective training and retraining on the subject of Lockout Tagout. Management should check if the training sessions held are addressing the fears and complaints that employees have, as well as teaching new ways to lockout tagout the machines and equipment. Unless the employees are trained and have hands-on experience, they will always find it burdensome and time taking. Training will help employees implement LOTO easily and work diligently.
Employees should be encouraged to actively participate in developing the energy control procedures that affect them. Line managers, supervisors, and workers should be involved with the lockout tagout as early as possible. Everyone concerned must have some ownership of the lockout tagout process to reduce resistance. Such involvement fosters a sense of ownership and helps to identify the issues faced on the shop floor. Once they believe in the ownership of the process, they will want to implement it and not hide behind the excuse of burden. Communication and feedback from employees should be sought continuously to identify both deficiencies in the lockout program and opportunities for improvement.
Lockout Tagout will always appear taxing if the LOTO system is not matured. Every company must have their LOTO policy and procedures drafted and thoroughly implemented. Older equipment should be modified to make them LOTO adaptable, and the level of implementation is most important. It should be a top driven approach. Procedures must be user-friendly and modified periodically based on the feedbacks of audit reports. Develop a plan to implement lockout tagout through all phases; management must know at each stage how workers are adapting or resisting LOTO. Check after the systems are in place, are people going back to the old way of doing things?
It should be a live, dynamic program with continuous improvement at all levels, and LOTO should be one of the non-negotiable safety norms, because "The Standard we set is the standard we get."
These five factors cannot be overstated in terms of ensuring the relatively smooth functioning of lockout tagout in the business. While accidents involving improper lockout occur for various reasons, they can generally be attributed to a lack of understanding and management failure. Errors such as inadequate training, poor energy control procedures, and a lack of lockout tagout program emphasize an increase in the likelihood of adverse events. In brief, organizations need to pay attention to MEP (machines, equipment, and processes), procedures, and human resources when integrating lockout tagout into their operations. They need to consider all of these factors early in the process of design. For example, if it takes more time to lockout the machine than repair it. Perhaps the machine needs a streamlined lockout procedure or a simpler way to isolate power for servicing and maintenance tasks. Considering LOTO burdensome, is a complete letdown for a company that aims for productivity and growth. Companies that have already made progress in tackling these issues see positive results in terms of higher productivity and a better safety record.
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