Guidelines for the control of hazardous energy are outlined in 29 CFR 1910.147. The standard covers “the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could harm employees,” according to OSHA. The standard “establishes minimum performance requirements for the control of such hazardous energy.”
Now is a great time to verify your lockout approach for accuracy and further improve its efficacy. Doing so can help you avoid serious injuries to your workers.
Here are five areas where you can look for improvements.
No. 1: Lockout Policy
When establishing your lockout approach, your company’s written lockout policy is the all-important starting point. It puts in place the essential elements for your overall lockout program. It should be the guiding document within any organization and is an OSHA requirement.
Within your particular facility, you should:
- Identify the types of hazardous energy that may be present in your machinery.
- Identify who will be isolating that hazardous energy.
- Ensure that you have the right equipment to isolate that energy.
- Identify who will train the employees assigned to isolate the hazardous energy.
- Identify who will write the lockout procedures.
- Describe the format for those procedures.
When establishing your lockout policy, also consider who takes on what roles and responsibilities. You should define:
- Who is assigned to do what? Who is going to be the overall administrator of the program? Will it be department managers or plant managers?
- Who is running the training?
- Who is auditing the procedures and your personnel?
- Who is writing the procedures and who is updating them?
- Your enforcement: What are the consequences for employees in non-compliance?
Also, make sure you spell out any exceptions to the policy. Are you allowing authorized people or your operators to conduct minor tasks under controlled power? And if so, have you gone through a hazard assessment under controlled power to ensure it is safe? Do you have any cord and plug equipment exceptions? Or single energy source exceptions?
Read more: OHSA-compliant Lockout/Tagout Procedures: Why the Rules for Hazardous Energy Are Worth Reviewing
No. 2: Lockout Procedures
This is the most important part of your lockout process because it allows an authorized person to follow a set of steps to properly shut down a piece of equipment and make sure there is no energy associated with it so it can be safely serviced or maintained.
If not done right, it could injure a worker or lead to a fatality.
Also important for lockout procedure is to include the scope and purpose of that procedure. What are the limitations? What does it apply to and for?
Is there any residual energy that is present when you are shutting down equipment?
What are the steps for verification of isolation? You need to note the magnitude of energy, too.
And as an additional help to your staff, including pictures of the isolation points and the equipment is also very helpful.
No. 3: Lockout Training
When it comes to lockout, we need to make sure employees understand their roles and responsibilities within the lockout program and how they interact with machinery in a safe way, so training is important, too.
Your employees should understand the company’s procedures and what the expectations for lockout are. Who is allowed to lock out equipment and who is allowed to work on equipment that is locked out?
Training should be targeted at three levels:
- Authorized employees (those individuals assigned by the organization to perform lockout)
- Affected employees (those who are working in the area where lockout is going on but are not participating in the lockout or maintenance of machinery)
- Other employees (workers such as office administration or janitorial staff within your building or facility who need to understand what to avoid)
- Contractors (who should provide documentation that they have been trained on lockout procedures but still receive an orientation on the company’s lockout process)
Training should include the basic elements of OSHA’s CFR 1910.147. Employees should also understand the equipment they will lock out. And if it’s found that employees have any deviation of behavior after training, they should be retrained in the basic principles of lockout.
It’s also worth considering creative ways to append employee training, such as through webinars or recent articles, to keep your employees up to date on the latest information about lockout.
The idea is to ensure they are not only current on the basics of lockout training but also on your company’s lockout procedures. If you keep up with training, you are complying with the lockout standard.
Read more: How to Communicate Effectively in Loud Workplaces While Wearing a Mask
No. 4: Auditing and Review
Your lockout procedures should be inspected at least once every 12 months to verify that the procedures are adequate and are being properly applied.
The inspection should have two components:
- An inspection of each energy control procedure.
- A review of each employee’s responsibilities under those procedures.
Each energy control procedure must be inspected separately to make sure it is adequate and is being properly implemented by the authorized employee in accordance with the lockout standard.
Energy control procedures used less frequently than once a year based on a 12-month interval need to be inspected only when used. That means if you have equipment that you don’t lock out in a 12-month interval, you only need to inspect it the next time it is used.
Read more: How to Tell When It’s Time to Replace Your PPE
No. 5: Equipment Strategy
In addition to proper training, companies should ensure they have a good lockout equipment strategy in place so that proper safety equipment (locks, lockout devices) is on hand and authorized employees are set up for success.
Two facilities rarely are the same, so there’s unlikely to be a one-size-fits-all solution for your equipment strategy. The needs of a large manufacturing facility will likely differ from that of a small metalworking shop.
For example, Master Lock likes to see a facility strategically deploy equipment based on the frequency of lockouts and the types of employees who are engaging in them.
Issues to consider when formulating an equipment strategy include:
- Who is doing most of the lockout work? Is it your maintenance people? If so, does it make sense to put the equipment nearer to them in a cart, or at the machine level?
- Would it benefit employees if you used shadow boards to identify where important lockout equipment, tools and other materials in common use are kept?
- Can you incorporate a lockout equipment plan with your manufacturing process to add another accountability level to lockout?
When Master Lock goes on-site to help clients it gives out equipment-recommendation documents that suggest a budget for the company and the equipment they should deploy.
The overall process of isolating energy from your machinery and equipment, when planned and executed well, can mean you’ll spend less on your equipment because you’ll be using it most efficiently.
CLICK HERE to explore product solutions that help maintain a safer workplace while working with electricity.
How are you making sure your employees are safe at work? Share your thoughts in the comments below.
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We follow all the rules. We have special locks for lockout. They are so special that they are either seized before we unlock them, or are unusable the second time. They say Master and specified for lockout. Plastic bodies anyone can remove with a pliers. They keep the honest honest.
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