Lockout/tagout (LOTO) procedures are needed before servicing or performing maintenance on equipment, machines or vehicles. They apply to situations that require control of hazardous energy when employees are involved in activities such as constructing, installing, setting up, adjusting, inspecting, modifying, maintaining or servicing. There are many requirements for implementing LOTO at a workplace, such as written procedures, audits and training. But the most basic expectation is the use of locks and hasps, which are not expensive or difficult to use. So why are there so many LOTO violations each year?
Perhaps the investment of time and money to train workers is too much for some companies, resulting in the workers’ lack of understanding of rules and procedures. Another contributing factor could be the safety culture within the company: does it encourage safe behaviors or are shortcuts a daily occurrence? Both these factors can and should be addressed by the employer and employees alike.
Preparation and procedures
The basic LOTO standards and procedures apply to situations where an unexpected startup of a machine or release of stored energy could cause injury. The requirements apply to all sources of energy, including mechanical, electrical, hydraulic, pneumatic, chemical and thermal. All this needs to be addressed when preparing and implementing LOTO programs.
It is worth remembering that LOTO doesn’t apply to all equipment. For example, electrical equipment that can be completely shut off by unplugging the power cord is exempt. But if there is a piece of equipment that can be unplugged but still contains pneumatic energy, this energy source will need to be locked out. In addition, the standard doesn’t cover the agriculture, construction and maritime industries, or oil and gas well drilling and servicing. Familiarize yourself with all the exceptions to the rules that apply to your industry before you adopt the three pillars of building and maintaining a successful LOTO program at your workplace.
The first step is to establish a program in writing. Designing the program requires documenting energy control procedures, which can be a lengthy endeavor, as the employer has to go through and identify all potential energy sources in machinery and equipment falling under LOTO regulations.
Once the person designing the program comes up with work-specific procedures, they need to ensure that these procedures cover all aspects of LOTO, including preparation, isolation, testing for hazardous energy, employee notification, and locking and removing the LOTO devices. As a result, preparation of the program implementation can be a long and involved process.
The second step is training. And when it comes to implementing LOTO procedures, training is vital. It’s not enough to train “authorized” workers while ignoring their “affected” or “other” colleagues. The work performed during and after lockout/tagout affects everyone in the area, so all employees should be taught the importance of LOTO regulations. Such training needs to be performed periodically, and employee participation and training updates should be recorded and certified.
The third step is for employers to monitor the workplace to ensure that the established procedures are followed and that the work culture isn’t influencing workers to disregard LOTO rules. If this is the case, additional training and rethinking the workplace culture may be required.
At least once a year the employer should review their program and organize inspections to establish if the program needs to be updated, changed or improved in any way. The inspections need to be conducted by authorized employees other than the ones using the procedures being inspected.
Company culture contributes to worker safety. If the culture encourages (or doesn’t actively discourage) cutting corners and taking shortcuts at the expense of safety, that workplace is guaranteed to experience some serious injuries—especially when it comes to lockout/tagout. The right culture will help ensure that a safety program is followed because a program on its own will not protect workers if they perceive it as a hindrance or think that there are more important things to do than comply with the rules.
But even if you have a solid safety culture, if workers are regularly rushed or complacent, they are more likely to inadvertently forget or consciously skip an important safety step. Decision fatigue can also settle in and influence workers’ actions without them even realizing it. This is why it’s a good idea to add human factors training to your existing safety programs. It will help workers be more aware of their surroundings and notice changes in their own behavior (such as being influenced by frustration or fatigue) that could influence their compliance with procedures. It will also encourage workers to watch out for their colleagues’ safety, contributing to an improved morale and solidifying safety culture.
Safe LOTO practices are influenced by the company culture, worker state of mind and time-sensitive priorities. This is why human factors training coupled with a high-quality LOTO program is a major step towards ensuring compliance. It can decrease the likelihood of incidents, lower insurance rates, and contribute to a healthy safety culture.