Why Lockout Tagout is not being deployed and followed in a right way

Despite established as one of the major ?administrative control ?, ? low cost and ?effective (if implemented right) risk control safety procedure, we still see lot of violations during lockout Tagout.

In US also lockout/tagout (LOTO) procedures account for one of the most-cited OSHA violations each year. In 2019, the LOTO Standard 29 CFR 1910.147 “Control of Hazardous Energy” placed fourth in OSHA’s Top 10 list of most-cited violations with 2,975 total violations; higher than the previous year.

?One foremost reason is employers failed to establish a comprehensive energy control procedure as per OSHA 29 CFR 1910.147 either partially or altogether. This standard outline minimum performance requirements for the control of hazardous energy during servicing and maintenance of machines and equipment. This standard establishes following five major components of the LOTO process:

1.????? LOTO Corporate Policy / Program

2.????? LOTO Procedures

3.????? LOTO Training

4.????? LOTO Inspection

5.????? LOTO Equipment

Most of the employers spend major resources just on buying and managing devices and get convinced that there LOTO process is all good. But it’s equally important to focus on other four elements of having right policies, right equipment specific procedures, training for all employees? and regular audit of the program. ?

As per OSHA, major violations have been

?? failing to provide adequate employee training,

??failing to conduct periodic evaluations of procedures, and

??failing to use LOTO devices or equipment.

Violations as per 1910.147(c)(4) Energy Control Procedure?

Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

Ideally, when employees follow the specific LOTO procedures, they are able to better protect themselves from unexpected re-energization or release of stored energy. But most of the organisations either rely on some Generic procedures or procedures which don’t have detailed information in line with requirement of the equipment.

Violations as per 1910.147(c)(7) Training & Communication?

When it comes to OSHA and LOTO, the code recognizes two categories of people that need training: Authorized & Affected Employees. Under the training mandated to companies by OSHA, “Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control. Each affected employee shall be instructed in the purpose and use of the energy control procedure.”

“Authorized employees” are those who are applying the locks and “affected employees” are those in the area during a lockout. The latter can range anywhere from operators to third-party contractors. If they are within the vicinity of the procedure, they are affected.

Violations as per 1910.147(c)(6) Periodic Inspection?

The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.

Right alongside training and communication lies the follow-up protocol of periodic inspections. Not only do employees come and go, but so does your equipment and the skill sets of the employee if the task is not performed on a regular basis. Annual auditing is a key component of maintaining your LOTO program in highest regard for safety and productivity.

Looking for a partner to implement Logout Tagout as per OSHA 29 CFR 1910.147, reach us at [email protected]