Like with many traditional processes, traditional ISCM is riddled with guesswork, human error and stacks of paperwork. I like comparing ISCM to accounting. In accounting, you have internal accountants, external auditors and a governing body that oversees the process. In the safety world, there is a combination of internal company inspectors and safety managers, third party inspectors and certifiers, and governing bodies who audit your processes.

Did you know that none of the top five most frequently OSHA-cited sections of the LO/TO standard is specifically about the protective materials and hardware? (i.e. the lockout padlocks and devices).

The top five sections cited by OSHA are:

(1) Failure to develop, document and utilize PROCEDURES;

(2) Failure to establish and implement a written PROGRAM;

(3) Failure to conduct a PERIODIC INSPECTION of the energy control procedure;

(4) Failure to provide TRAINING as described by OSHA;

(5) Failure to clearly OUTLINE the SCOPE and rules to be utilized, and the means to ENFORCE compliance.

That’s not to say that the products designed and used for lockout aren’t important, as they certainly are. It does, however, speak to the fact that lockout compliance is first and foremost about having a sound program and machine-specific procedures in place, along with comprehensive training and effective communications for your employees.

Lockout/Tagout is a major OSHA-inspection focus. In fact, it’s the #1 most cited violation for general industry. But, rather than focus on the negative aspect of noncompliance and citations, focus instead on this; comprehensive and thoroughly-followed LOTO programs:

• SAVE LIVES – preventing an estimated 250,000 incidents, 50,000 injuries and 120 fatalities annually;

• CUT COSTS – significantly; both lost employee time and insurance costs;

• IMPROVE PRODUCTIVITY – minimizing equipment downtime;

• BEST PRACTICE – being widely adopted across industries and industrialized countries

Four-Step Plan

Do you want to be in compliance with both the letter of the OSHA law and the spirit of it so as to provide a safe work environment for your employees? Certainly. One way to accomplish both is to use the following four-step plan to help create your energy control program. Doing so will both bring your organization into compliance and put you on the road to the greater benefits noted above.

• STEP 1: Develop and document your energy control program and written procedures;

• STEP 2: Identify and mark all energy control points;

• STEP 3: Train your employees, communicate and conduct periodic inspections;

• STEP 4: Equip your employees with the proper lockout tools and warning devices.

Program Development and Procedures

Synopsis of Regulatory Standard: According to 29 CFR 1910.147 (c)(1), the employer is to establish an energy control policy/program consisting of energy-control procedures, employee training and periodic inspections to ensure that the machines or equipment are properly isolated from their energy sources, and rendered inoperative prior to any servicing or maintenance.

29 CFR 1910.147 (c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in locking out equipment. A separate procedure must be created for each piece of equipment, or each group of similar equipment as defined, except for equipment that meets a rigid set of exceptions.

Related Incident & OSHA Citation: October, 2007; OSHA proposed $112,500 in penalties to a large employer for repeat violations, including failure to develop proper energy control procedures.

Less than three months earlier, the same organization was cited for $2.78 million in proposed fines for 42 willful violations of the lockout/tagout standard, including failure to utilize lockout procedures before attempting to clear equipment jams, and failure to provide training to four employees responsible for clearing jams. Tragically, an employee had been killed in a related accident.

Successful Program & Procedure Development: The written lockout policy is your starting point; it establishes the ‘nuts and bolts’ of your overall lockout program. Begin this by over viewing and then documenting your program; continue with machine-specific procedure development, training and periodic inspections. OSHA has a Lockout/Tagout Tutorial on its www.osha.gov website that provides additional advice.

Also see Brady’s Lockout Pro Graphical Lockout Procedure Software for a thorough sample energy control policy that can serve as a guide as you develop your own comprehensive energy control program. However, the overriding benefit of Lockout Pro is that it allows you to create and manage clear & easy-to-follow visual machine-specific procedures for all your equipment.

Energy Control Points

Synopsis of Standards: According to 29 CFR 1910.303 (e) and (f) Subpart: Electrical, all disconnecting means must show the magnitude and shall be legibly marked to indicate the purpose.

ANSI Z244.1-2003, Control of Hazardous Energy, states that all energy isolating devices should be adequately labeled or marked unless they are located so that their purpose is clearly evident. Identification shall include the machine supplied and the energy type and magnitude.

Related Incident & OSHA Citation: November, 2002, OSHA cited a manufacturer for failing to protect workers from electrical hazards that contributed to the death of a worker. The employee was working on electrical equipment that had not been properly labeled and disconnected. OSHA issued a willful citation for failing to properly label electrical equipment, and a serious citation for failing to have adequate procedures in place to render machinery inoperable while maintenance and repair work were performed.

Successful Energy Control Point Identification: Locate and mark all energy control points, including valves, switches, breakers and plugs, with permanently placed labels or tags. Cross reference each label and tag with the corresponding step number in the posted energy control procedure for that equipment. Include information about the magnitude and purpose of the control point as stipulated by OSHA for electrical disconnects and recommended by ANSI for all isolating devices.

Training, Communication & Inspections

Synopsis of Standard: 29 CFR 1910.147 (c)(7) requires an employer to provide training to ensure that the purpose and function of the energy control program are understood by employees … (iv). The employer shall certify that the employee training has been accomplished and is being kept up to date …

Standard: 29 CFR 1910.147 (c)(6) The employer shall conduct a periodic inspection of the energy control procedure at least annually.

Related Incident & OSHA Citation: August, 2007, OSHA conducted an investigation following the death of a fleet mechanic who was pinned between two trucks while performing maintenance on one of the vehicles at the company’s worksite.

“This was a preventable tragedy” stated the director of OSHA’s area office. OSHA issued one willful violation for alleged failure to implement and train employees on a lockout/tagout program to be used when performing vehicle maintenance.

Successful Training, Communication & Inspections: First, establish formal training programs for each of the three categories of employees for lockout: ‘Authorized’, ‘Affected’ and ‘Other’ employees. OSHA provides advice on how to train, and verify that the training is up-to-date.

Programs like Brady’s Lockout Pro includes a training module and employee quiz that can be administered upon completion of your employee training. It also provides a straightforward explanation of the periodic inspection requirements.

Proper Protective Products

Synopsis of Standard: 29 CFR 1910.147 (c)(5) says lockout devices must be provided by the employer, be standardized by size, shape or color, be distinguishable from locks used for other purposes, identify the individual who applied the lock, be durable, be strong enough to prevent removal except by using excessive force, and remain under the exclusive control of the individual who attached them.

29 CFR 1910.147 (c)(5)(iii) says that tagout devices shall warn against hazardous conditions if the machine or equipment is energized and shall include a legend such as the following: Do Not Start … Do Not Operate.

Related OSHA Citation: March, 2007, OSHA opened an investigation after receiving notification that an employee was crushed while servicing a hydraulic press that had been disabled but not protected against accidental energizing by locking out potentially hazardous energy sources.

OSHA issued four willful and 15 serious citations, alleging, in part, that the company failed to control potentially hazardous energy during machine repair or maintenance, and was deficient in having personal identification of lockout devices.

Equip Your Employees with the Proper Lockout Tools & Warning Devices: Ultimately, it’s the proper and religious application of the lockout hardware per the established procedures that makes for a successful lockout program. To this end, it’s very important to know and document specifically what devices are acceptable for use at each and every lockout point.

There is a tremendous range of sizes and shapes of valve operating handles, circuit breaker switches and various other energy control means. Leading lockout device providers will have developed product series that properly fit the majority of these.

It’s not just about the products, and it’s not just about avoiding a fine:

Establishing and maintaining a comprehensive Lockout/Tagout program that is understood and embraced by your employees will cut costs, improve productivity and, above all, potentially avert an incident or employee injury. FSM Tom Campbell is senior marketing manager of Brady Corp. For more information on Brady’s lockout solutions, go to www.bradyid.com/lockouttagout. Or call 1-888-272-3946.