Are you one of the lockout tagout greats?
What happens beyond a lockout tagout (LOTO) program implementation is what separates the rare few greats from the rest of the overworked industry.
- Are your lockout tagout procedures updated to reflect changes and upgrades in your facility?
- Do your production lines have specific isolation valves and electrical disconnects in place?
- Are you conducting annual LOTO procedures audits? You would be surprised to know the answer to this question is often no.
- Are you enlisting qualified professionals to conduct a gap assessment on your procedures? This is a critical step to the effectiveness of a LOTO program. Why? Because the annual audit process becomes is often seen as yet another task for burdened safety professionals leading to oversights.
Scaling can break even the best LOTO programs
Enterprise growth can also become the root of many challenges, mainly if safety programs are not correctly scaled. Growth outpacing safety programs is one of the main reasons the 1910.147 control of hazardous energy (lockout/tagout) is on the top 10 list of OSHA’s most cited standards year after year.
LOTO Enforcement
In 2020, OSHA assessed a proposed $7.5 million in penalties for violating the LOTO standard, making it the sixth most frequently cited agency standard. Food manufacturing, fabricated metal products, plastics and rubber products, wood products, and primary metal manufacturing are the most heavily penalized industries.
Common LOTO Procedures Oversights
Conducting LOTO gap assessments helps you ensure the procedures in place can protect employees from injury and equipment from damage. Thorough annual audits identify procedure adherence gaps. The problem is that in-house personnel can miss critical items when performing these gap assessments due to the mounting demands on safety professionals. Some of the most commonly found oversights include:
- Incomplete documentation of required lockout tagout training
- Failure to update procedures to reflect changes in operations and equipment
- Failure to release equipment stored energy
Be Proactive
The world of LOTO is changing. Traditional control measures such as physical locks and tags are being challenged by computer-based controls as the workplace environment becomes more automated and digital. Most industrial environments rely on multiple energy types ranging from electrical, thermal, and gas to radiation, vacuum, explosive, and propellants; each source calls for a tailored safety approach. Knowing that a revised OSHA standard is in the works, our advice is: to be proactive with our digital lockout/tagout program.
Use internal experts from different departments or a “fresh pair of eyes” from a third-party service to assess if gaps exist between your written procedures and program and your sources of energy, control procedures, labeling, data collection, and training. Remember that there are tools and software available to help you update and build a best-in-class LOTO program to protect your people and equipment.
Read our full Taking a Deep Dive into the World of Lockout Tagout article in OH&S Magazine.
SEAM Group: Your Comprehensive Lockout/Tagout Partner
LOTO Program Development and Implementation
Each LOTO program is custom developed for compliance with the applicable OSHA regulations and standards as well as your company’s specific requirements and policies.
Annual Audits and Reviews
Verify that Energy Control Procedures (ECP) are accurate and that employees are able to demonstrate proper energy isolation of equipment to perform servicing and maintenance.
Compliance GAP Assessment
An in-depth report of where your LOTO program to identify and make recommendations on overlooked areas, training gaps, and improvement opportunities