Properly locking out machinery to complete tasks where sudden activation could be disastrous is challenging enough for one person. Add in a group of people who need to work together to complete complicated repairs or necessary servicing, and the stage is set for miscommunication or human error that can lead to someone being in a dangerous situation if premature startup takes place. In order to create a safe working environment for everyone, the solution has been and continues to be the practice of group lockout/tagout techniques that afford equal protection to all involved with the work being done.
Over the years, I've worked with many industries trying to refine their group lockout practices and adapt to the ever-changing dynamics of new people, machinery and processes, tighter schedules and increasing compliance requirements. For clear guidance on group lockout practices, I highly recommend chapter 4 of OSHA's compliance guidance document, CPL 02-00-147 The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures
Another extremely helpful guidance document, which is about to be released in a significantly updated version this fall, is the 2016 version of ANSI/ASSE Z244.1 The Control of Hazardous Energy - Lockout, Tagout and Alternative Methods. Chapters 7.10, 7.11, Annex J and Annex K address group lockout considerations.
This has been the benchmark standard for lockout/tagout for three decades, and the valuable insights on methodology will be helpful to your planning and preparations to protect multiple people or crews during complex maintenance or repair assignments.
Success with group lockout skills starts in your written compliance program. How complex does your work get? The OSHA CPL and ANSI/ASSE Z244.1 references are excellent for starter language to identify what you expect to do at your facility. Take the applicable techniques you think you will use and write them into your lockout program, either in the body of the policy or as an annex.
Then, teach your specific program. A question I ask in our end-user assessment process is, "How detailed is the group lockout methodology you provide in your authorized training courses?" The answer often is, "Not very."
Run real-world group lockout drills in the classroom, or take workers to actual machines and put them through the paces of locking into and properly exiting a group protective system.
During group lockout, management must keep an eye on active applications. If the crew has it right and everyone is safe, make sure you let them know. If the crew is underprotected, find out why. Often, it comes down to not being set up to succeed: not knowing how, limited time or insufficient equipment. These all are common themes that can prevent crews from safely getting their work done.
Without question, detailed and written lockout procedures are a must for any group lockout system. That means a consistent, applicable control method must be understood and used. If two workers disagree on the correct method to secure a specific machine, it means one is wrong or both are. Reliably applying group locks, releasing residual energy and effectively checking for zero energy is not a good development activity by committee. Good written procedures put everyone on the same page.
Problem with Unprepared Employees
A typical problem I see when counseling companies is employees coming to the task unprepared to set up or join in a group lockout operation. Only when the task clearly is known to require one person to complete the assignment should locks be directly attached to energy isolation points like breakers and valves.
Many simple jobs often require an extra set of hands for at least a short period of time to get the job done, and asking for help with the originator's lock blocking the participation of a short-notice helper forces the additional person to work under the protection of the lead worker's lock. You can, of course, remove the one lock (per isolation point), add a group hasp and make room for each participant to add his or her protection. But remember, this is short-term activity, and to release the lockout and reapply the lockout with an additional safety equipment requirement often is viewed as a conflict to getting the job done rapidly.
The solution? Make it a requirement to place a group hasp in each isolation point being controlled. Then place a personal lock to secure it. This will allow, whenever necessary, a short-term authorized helper to add his lock immediately into the safety system, test the controls for zero movement and go to work to assist with the task. When the authorized helper's work is complete, he can remove his lock from the hasp(s) without the original worker's safety being compromised or distracting their focus on the task being completed.
Truly a best practice, which I have been impressed with at a number of very progressive businesses, is the tethering of gang hasps to common isolation points; so they always are right there and ready to go. That way, there is no question whether they will be brought to the task location or applied preemptively in anticipation of authorized helpers joining in.
We know that any time two people work together to isolate two lockout points, it becomes an equal use of locks when compared to the use of a group lock box. Any time there are more people or more points, it stands to be more efficient to use group lock box practices because applying fewer locks requires less time and reduces the error of leaving personal locks behind that will then require complicated emergency removal procedures.
On the subject of group lock boxes, there are some things to take into consideration. What is the true pace of compliant group lockout activity in your workplace? Is it frequent enough that group lock boxes immediately need to be available at the department level, or can traveling lock boxes be brought to the task site in a timely manner each time they are needed? I particularly was impressed with one food-processing company that had sanitation line leaders lock out each piece of machinery ahead of the arrival of the cleaning crews, allowing them to lock into the box, test to zero and complete their work safely. By the time the crew was finished, the next machine in line was secured and waiting for them. The line leader's eyes surveyed the active task being performed. The group lock box on the machine where cleaning was just completed was then moved ahead to the next machine in the line – an efficient process, with uniform and continuous protection for all.
If the scope of your work shows that group lockout will be a frequent and/or complex activity with large or mixed groups of workers (i.e. contractors and employees, or various crafts), coordination is a must. One way to improve workplace efficiency is to have a number of group lock boxes, each individually identified, with a designated set of keyed-alike locks marked as being part of that box set and stored inside. When a machine needs to be locked out, the lockout leader, following the written machine-specific procedure, applies the locks in order to the group hasps at the isolation points using one key common to all locks. The lockout leader then secures the one box-set key within the lock box, along with any unused locks, applies his personal lock to secure the box, and tests to zero movement.
A second verification leader independently repeats the process with a different lock set, places his set key in the lock box and attaches his personal lock. Each member of the lockout group joining in should be given an opportunity to check that the procedure has been applied correctly. However, OSHA does allow for representative verification to be accepted by group members. This can bring workers the necessary confidence to cycle in and out of the group safety system as they individually begin and end their assignments.
There is no one-size-fits-all approach to group lockout. But, if employers follow the management model brought forth in the ANSI Z10 Safety Management Systems Standard – Plan, Do, Check, Act – a site-specific group lockout plan reliably will offer protection to workers.
PLAN: Have a written program that details your plans for group lockout activities at your facility. Have a lockout equipment plan in place that meets your machinery/process needs.
DO: Prepare your workers (and tradespeople) by job-specific training backed with detailed and well-tested lockout procedures. Locate the LOTO equipment for easy access.
CHECK: Verify each group lockout by testing for zero energy. Have at least a second set of eyes also verify. Have leadership routinely inspect active group lockout operations to congratulate good safety continuity or correct insufficient protection.
ACT: Share what is learned with those authorized in group lockout. Continuous improvement comes from accepting lessons learned to overcome misunderstandings and lack of knowledge, addressing equipment needs and turning apathy into participation.
Successful group lockout is achievable. By following these practical techniques, you'll effectively come together to get the work done right, on time and under the protection of well-applied group lockout practices.
Todd Grover is global sr. manager for Applied Safety Solutions at The Master Lock Co. He has over 30 years of experience as a practicing safety professional and EHS manager. His experience with a wide range of industries has involved the preparation of numerous lockout policies and detailed procedures, company-specific compliance training, accident investigations, and acting as the representation of many employers during OSHA citation cases. Todd is a participating member of the ANSI Z244.1 committee on Control of Hazardous Energy, as well as a delegate to the U.S. PC283 committee contributing to the upcoming ISO 45001 Global Standard for Occupational Health & Safety. Contact him via email: [email protected], or reach him at (414) 571-5625.