This article by Ray Prest was originally published in the July/August 2021 issue of Occupational Health & Safety.
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 every safety professional 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.
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 you except to do the (expletive) training until it sticks. Stop reading right now and figure out how you’re going to educate workers on the proper lockout/tagout procedure as soon as possible. Don’t let organizational pressures cause you to rush through the development of the procedures (like using one generic procedure to cover differing equipment or situations) or take a shortcut on the training due to operational time constraints (like only training authorized employees and not affected ones). Full stop.
The other issues are a bit more nuanced. Sometimes there are systemic pressures that induce employees to work fast, enough to increase their risk of omitting some or all of the steps in controlling hazardous energy. More often than you’d like, an organization doesn’t take sufficient steps to combat people’s natural tendency to forget things. These issues can be addressed by better using supervisors’ natural position as the liaison between frontline workers and organizational systems.
Supervisors are able to communicate above to operations and safety managers, below to individual employees and laterally to maintenance personnel. When production demand requires a sustained period of working at a faster pace than normal, supervisors can deliver additional just-in-time safety reminders to workers while also letting management know when rushing and other human factors build up to a degree at which they’re seriously compromising safety.
Supervisors can play a similar role when it comes to managing LOTO-related complacency. Frontline leaders can keep an eye out for signs of non-compliance and pass their observations up the chain, while also providing timely reminders of the need to control hazardous energy on the shop floor. This is especially important because near-misses—which are an early warning sign of complacency setting in among workers—are much harder to catch for lockout/tagout. Relying on supervisors allows the safety manager to be more proactive about stemming the tide of LOTO complacency.
Additionally, supervisors can help combat the forgetting curve—the fact that people forget roughly 90 percent of something they’ve learned within a month. If your lockout/tagout training is limited to a single class or a once-per-year event, then you need to account for that in your plans. Create checklists, posters and get supervisors to provide reminders after the classes. Get people to recall and communicate the procedures to you during walkthroughs and inspections and ask supervisors to do the same on a regular basis. Critically important issues like LOTO can’t be left to memory, and supervisors have the daily rapport with employees that they can leverage to provide frequent LOTO reminders.
Supervisors and Individual Interventions
Supervisors are also able to support stronger individual skills among workers through one-on-one conversations. It’s a rather simple but powerful form of intervention: whenever a supervisor notices a potential LOTO issue brewing, they pull the employee aside to have a positive, constructive conversation that’s designed to improve future behavior. This is particularly useful when lockout/tagout procedures are compromised by human factors like rushing, which are ‘sometimes’ problems for many companies. Mental and physical states fluctuate throughout the day, and workers likely only rush through the LOTO process some of the time. Given their vantage point at ground level, supervisors may be the only organizational leader who can spot the issue and intervene.
In lockout situations where multiple people are involved (such as authorized employees, affected employees, a maintenance person and/or contract equipment technician), supervisors can be pivotal in offsetting group issues that can arise from a lack of communication, ambiguity around who’s doing what, inaction due to distributed responsibility and rushing.
Many studies have shown that as the number of people in a group increases, individuals are less likely to act, intervene or even see an emergency developing. This happens because individuals in groups tend to look at others for cues, assume someone else will act, or they follow the lead of the person of authority. An affected employee may not speak up because they think the authorized employee must know what they’re doing. This behavior is amplified again by rushing. The famous Good Samaritan study showed that “being in a hurry” was the single strongest determinant in whether people would get involved in others’ situations. A supervisor can combat this by being the central authority and over time building a psychologically safe climate where speaking up is the norm. Having robust human factor knowledge among all staff makes it easier to see how anyone can make a mistake, miss an important step or take a shortcut under routine or extreme situations.
If there’s one big catch with the standard lockout/tagout procedure, then there’s also a catch with using supervisors as part of the solution. For frontline leaders to effectively reduce LOTO-related issues, they need good communication skills, strong safety knowledge and a well-rounded understanding of human factors like rushing and complacency. You don’t need me to tell you that relatively few supervisors possess all three.
There are several ways to help your company’s supervisors learn more and improve their skills, from micro-learning and targeted education to more wholesale supervisors training centered on human factors and developing the ability to intervene. While each has its merits, the most important decision you make isn’t so much how you train supervisors as it is to recognize that lockout/tagout compliance and supervisory skills may be a lot more closely aligned than you think.
Ray Prest is the Director of Marketing at SafeStart, a safety company focused on human factors solutions that reduce preventable death and injuries on and off the job. A columnist for Safety Decisions since 2015, Ray’s been helping people learn about safety and training for over 20 years. Read more at safestart.com/ray.