Besides risking OSHA citations and fines, it's no secret that preventable lockout/tagout (LOTO) incidents can cause worker injuries, damage equipment and facilities, disrupt production and even put your company out of business. However, no company wants to spend more than they need to nowadays, especially on “non-productive” items that don't directly add to the bottom line.
The good news is there are several things you can look for beyond basic lockout functions when evaluating and selecting LOTO energy isolation devices, padlocks, tags and signs that can simplify your LOTO, save time and energy as well as money, and also help ensure that A) devices get used and B) that lockouts are effective.
Several major manufacturers offer a full selection of products to meet virtually every LOTO need, but all devices are not created equal; some work more effectively than others. And some lockout environments pose special challenges that if not addressed, potentially could render certain devices ineffective. We will focus on important device differences, workplace environment and real-world worker scenarios and point out plusses and minuses to help guide and expedite your LOTO device search.
DOING THE JOB RIGHT
Along with OSHA requirements such as effective, durable and identifiable lockout devices and activities, several additional factors to consider are noted below, followed by examples of how OSHA and related issues could impact your choices.
Simplify LOTO with multiple-application devices. Look for energy isolation products that can be used with more than one type of switch, breaker or valve. With fewer items to inventory and fewer items for workers to carry, there is less chance for confusion. And, importantly, less chance of a worker trekking to a lockout point with a 1-inch device only to discover that he needs a 2-inch device and either having to make the trip again or worse, deciding to proceed without locking out the energy source.
Ease of use
It's been said, “If it's easy to use, it will get used.” Some lockout devices may be difficult to close or hard to fit onto or around items that need to be locked out. Such situations not only frustrate workers, but can result in less-than-effective lockout — or tempt the worker to skip the procedure altogether.
While space-saving devices require less shelf and toolbox space, the primary objective here is to look for device designs that more easily accommodate space limitations that workers may encounter at various lockout points.
This suggestion focuses on LOTO environmental issues (chemicals, temperature, etc.) relating to signs, tags and labels, especially those that carry a common message (e.g. DANGER!) along with variable day-to-day worker identification and application info.
Keep in mind that “durability” in LOTO means not only the strength of devices themselves, but also their ability to withstand harsh environmental conditions such as high temperatures or contact with chemicals used in plant processes, cleaning and maintenance.
Here's how these considerations could play out with various LOTO applications and devices.
VARIETY MAKES A CASE FOR SIMPLICITY
There are numerous ways to cut the power, which presumably require different devices to effectively lock out electricity, but not as many as you may think.
Circuit breakers — Some manufacturers provide about half a dozen devices that each fit different breakers and there's nothing wrong with that. Other devices available on the market fit both wide or tall breaker toggles usually found on high-voltage/high-amp breakers or that fit both standard height and tie-bar toggles typical of 110- and 240-volt breakers.
Gripping strength — Don't take specific lockout device “gripping strength” for granted. We've seen some that clamp onto a breaker but easily can be pulled off or fall off if a hasp and several steel locks are attached, thus unlocking the lockout. Look for a device that you can dial in to tightly fit the breaker, providing a vise-like grip when you close the latch.
Electrical plugs — Look for as few devices as possible to cover various plug sizes and voltages. The ability to withstand high temperatures and chemicals often is an issue, so seek out durable thermoplastic devices. Ask for reusable “Danger” and worker I.D. labels, too.
Space-saving device design is another big plus with some plug lockouts. Look for the circular type device that rotates in/out to surround the plug. It makes application easy, especially in tight places, and also requires less storage space.
Wall switches — It's not unusual, especially as plants or equipment are expanded or upgraded, for traditional toggle switches to coexist with more contemporary designs. We suggest you look for a lockout device that easily adapts to accommodate either type. This fits multi-use “simplify” criteria and ensures that your workers have the right tool, no matter which switch they encounter.
An almost endless variety of valve sizes, valve location and space limitations, high temperatures and harsh chemicals are among challenges that need to be addressed in order to effectively lock out valves.
Gate valves — Most lockout devices (especially for larger valves) are cumbersome and difficult to install with pipes close to walls or ceilings. Here's where a rotating device design (similar to the plug lockout noted above) could pay in several ways. It requires half the storage of a typical device, and rotates comfortably around valves in close quarters. Also, different sizes of these devices “nest” within each other when open; on-shelf or in a toolbox, one “half-moon” device can house a full set!
Look for a durable, chemical-resistant thermoplastic material that's able to take the heat (300-400 degrees F) and shrug off chemicals.
Ball valves — Temperature could be a big issue here. While plastic lockout devices work fine for many applications, we've seen instances where heat from a steam pipe valve literally melted one such device. Oil also can pose heat issues. So know the temperatures with which you're dealing. And make sure you have at least a thermoplastic LOTO device or, even better, opt for an aluminum or steel device. One such device that we've seen can handle temperatures up to 1,000 degrees F; this single device clamps tightly around handles on valves ranging from ¼-inch to 4-inch.
Another frequent ball valve issue is the wide variety of valve handles, including some that are 15 inches long and 3 inches wide, from a bevy of valve manufacturers. A multi-valve lockout solution fits virtually any valve installation. Such a solution is ideal where pipes are next to walls, ceilings or other pipes. Simply remove the valve handle before applying the device with a wrap-around strap and lock, and secure the handle inside a pocket on the device.
This type of device also provides an important “bump-proof” solution. If the handle is on the valve and a wedge- style lockout device is not tightly applied, it accidently could be bumped, opening the valve. Even if the valve opens only 10 degrees, high-pressure steam or escaping ammonia or whatever else is in the pipe could create major problems. Removing the handle and using the handle-off multiple valve lockout device removes that risk.
CABLE LOCKOUTS, PNEUMATICS AND MORE
For virtually any application, there are ways to simplify LOTO and ensure fully effective lockouts.
If you have multiple valve or electrical power boxes, rather than using individual hasps and locks, use one cable that cinches tight after lockdown to ensure a proper fit. Look for multi-stranded steel with a plastic coating to prevent scratches and sparks (a critical issue in some environments).
With umpteen valve fittings, most manufacturers offer multi-use devices. Some even offer virtually a one-for-all device able to lock out a seemingly endless array of pneumatic fittings.
Make sure you get adequate handle overlap to accommodate multiple worker locks. We've seen some hasp applications where hasp jaws did not remain closed even with a lock attached, allowing the hasp to be slipped off.
Whatever padlock colors you use for various departments or other applications, choose a different, distinctive color to clearly identify lockout/tagout — the brighter, the better. “Danger” labels with employee name or photo are good, too.
“One worker, one key” is the LOTO rule, and most manufacturers routinely ship just one key per LOTO padlock. Check out manufacturer key charting services, critical for ensuring that subsequent padlock orders contain no duplicates. Locks that are able to handle thousands of key changes also ensure non-duplication in virtually any size workforce.
When you have several supervisors and many more workers maintaining a line, securing all keys during lockout procedures is a must to ensure that no one unlocks and starts anything until everyone agrees that the work is done.
Look for boxes that are truly secure. One popular design has a slide-back button, so a padlock applied anywhere keeps the top from being lifted, and contents securely locked inside.
You'll find many ways to put specific LOTO products at workers' fingertips.
When considering personal kits, look for lockable options with assorted products, and makers who can custom-assemble electrical or valve lockout kits, for example.
Placed by a machine or elsewhere in a department, most multi-use lockout stations accommodate the devices, hasps, tags and padlocks needed for that area. Look for stations with a lockable cover to keep out dust and grime while also preventing lockout padlocks from being borrowed for other uses.
Lockout execution is only part of the job. LOTO communication is the other part, and a crucial part, at that.
We already noted that you need unique padlock colors to instantly identify LOTO. When it comes to tags and signs, OSHA recommends or mandates specific colors and combinations for “Danger,” “Caution,” “Warning” and the like, as well as how they may be displayed.
For some employers, the goal is long-lasting signs that can stand up to chemicals, dirt and grime, heat and any weather conditions. Others prefer to order/reorder paper signage for variable worker and procedure info, or to buy laminated items and fill in specifics by hand.
We recommend searching for signs and tags where the constant messages are fused into plastic. We're told that signs employing this type of technology have been tested to withstand over 30 chemicals found in facilities, and lasted more than 4,000 hours under QUV outdoor environmental tests (sunlight, rain, condensed surface moisture), which is equal to 10 years outdoors. You also can write today's worker/procedure info boldly with permanent markers, then wipe it off with plain alcohol for the next shift.
In addition, more organizations today seek photo-image quality with tags, as worker photo-I.D. gains usage.
Diverse work forces often are the norm nowadays, including employees who may not be directly involved with LOTO activities, and clear LOTO communication with all employees is every employer's obligation. Some LOTO manufacturers routinely provide bilingual or trilingual (English/Spanish and/or French) labels or signs and can customize signs in numerous other languages.
Obviously, we haven't covered every type of LOTO product or every detail of those we did include. But looking for devices that simplify LOTO, save space, are easy to use and are reusable can save your business money while ensuring that you meet OSHA requirements for effective, durable and identifiable LOTO procedures.
R.E. Schingoethe is an independent consultant and communication specialist who has covered industrial, commercial, utility and institutional safety and security issues for more than 15 years in print media and web venues. He has co-authored on-line training programs and webinars for the American Institute of Architects via Hanley Wood University and the National Apartment Association Education Institute.