As the gavel slams down, the CEO of the medium-sized pharmaceutical company looks down in disbelief. They lost the case before the Supreme Court and now they have the tough task of rebuilding morale and their (obviously inadequate) lockout/tagout (LOTO) program. The judges determined that the company's non-compliant LOTO program was to blame when a large autoclave that was being serviced inadvertently was re-activated remotely by a control room operator, killing three workers.
The company has a new attitude towards safety now and a new safety budget. The board of directors determined that they were going to completely revamp their LOTO program in house, starting from the ground up. After such a horrific tragedy, everyone in the company — from management to line employees — is looking for answers. Not only about what happened, but more importantly, how can they ensure it never happens again.
When an accident of this magnitude occurs, the knee-jerk reaction by upper management is to button up their policy and restrictions so tight that they don't allow for the most important element in safety — the human element. Because there's no way to write a policy that covers every possible scenario that authorized employees will encounter, it's more effective to help teach and enforce an approved approach towards the likely scenarios that will be encountered in their facilities.
CIRCUMVENTING EXCUSES
The result of making a policy and program too restrictive: more accidents. When we give trainings around the country in different industries, we hear the same valid concerns brought up when we help implement the new LOTO program or come in to help after a program has been made too restrictive:
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How can I be expected to lock it out when it needs to be partially energized to do my service work?
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When I lubricate the chain right now, it takes me 5 minutes. If I have to lock it out each time I lubricate each part of the chain it now will now take me longer than an hour.
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Our equipment jams up three to five times an hour and I have to clear these jams to keep product moving. It takes me less than 30 seconds to clear the jams right now, but if I have to lock it out each time, it will take hours and production will suffer greatly.
The list goes on, but the common theme is that authorized employees don't realize that the program implemented to save their lives is practical. And management does not do a good job of explaining the value of the LOTO program, simply saying, “Do it.” Then the employer realizes that they're paying a cost for the program and production is down or accidents are up or both.
So what is the answer? As a manager, how do you ensure your employees are safe without damaging the business? As an authorized employee, how do you get your job done safely without taking so long to do simple tasks?
The answer is simple: Allow employees to make decisions, but make sure the decisions are guided by a firm understanding of what is and isn't allowed.
It won't be the same, specific answer for every company or industry. OSHA provides guidelines in the regulation that must be followed and employers are expected to find a good fit for their business while staying within these parameters.
SOLUTIONS
Here are some solutions that might surface from an authorized employee working under a high-performance, employee-driven LOTO program:
Partial energization: Steve, an authorized employee, realizes that to program the robot properly, he needs to be inside the guarding and very close to the robot and part. He remembers from the company policy and training that he can perform this task if he ensures he has the equivalent level of safety that a full lockout would provide. Since this service only is related to training the robot, he ensures he has the only control pendent and thus full control of starting/stopping the robot. He now can safely and legally be inside the guarding and close to the equipment while conducting this task.
While programming the robot, Steve realizes that there is an air leak on the lower robot support arm. To fix this leak, he would have to shut off the upstream air and replace the leaky fitting. He knows from company policy and training that if he's performing non-routine maintenance, he must lock it out, so he follows the machine-specific LOTO procedure posted on the equipment and brings the robot down to zero energy state within minutes to safely perform this task. The entire task took less than 30 minutes and he knows this is the preferred company methodology to keep him safe.
Minor Maintenance: Allen, an authorized employee, returns to work after annual refresher training to perform a simple task of lubricating a long chain on a product conveyor. This task previously only took him 5 minutes because he wiped the lubricant on as the chain was moving. But he learned in training that if you remove guards or put your hands in the moving path of the equipment, you must lock it out.
Allen knew locking it out wasn't practical. His training instructed him to make management aware of such issues, so he brought it up to his safety manager and they worked out an alternative: They modified the guard to have an opening so that a lubricant extension rod could be inserted while the chain was moving to lubricate it just as efficiently as before. Using tools to keep your distance will allow you to safely avoid a lockout entirely.
Clearing a jam: Debora, an operator of the equipment and an authorized employee, was in charge of running a large case packer. From time to time, the cardboard boxes would jam before they were filled, causing the equipment to stop. To clear the jam in the past, she would just hit the e-stop button and grab the boxes that were jammed and get the equipment running in less than 30 seconds.
The equipment was designed to allow this to be done safely, but after her training, she discovered she was placing her body in harm's way every time she cleared a box. Even though the equipment wouldn't move while the task was being performed, she was not in control of the equipment — she needed to lock it out. Locking out all four disconnects each time it jammed would cause the company to lose a lot of money in production, but she didn't know how else to do it. After trying to use a tool to clear the jam, it became obvious that she needed to clear the box with her hands. A customized machine-control procedure was developed for clearing the frequent jams on the equipment. After extensive analysis, it was determined that turning off and applying a lock to the local electrical disconnect provided an equivalent level of safety as a full LOTO for that specific task. They also took it a step further by permanently fixing a lock near the disconnect so that it only took her 20 seconds to lock out the main electrical and attempt to restart to verify it was in fact inoperable. Then she could safely clear the jam and return the equipment to full service in a matter of less than 1 minute.
To truly get the most from your LOTO program, authorized employees must be taught how and when to lock out the equipment and also what to do when they encounter something out of the ordinary. A high-performance LOTO program is designed to change and update as the workplace changes. With employee involvement, these changes and updates will occur organically and be much more practical than if it all fell on the safety manager's shoulders.
A policy that is too restrictive only will lead to more accidents because employees will invent shortcuts to get the job done, or they will follow the policy as written and production may drop so dramatically that it will be difficult to stay in business.
With a good understanding of the regulation's intent, a LOTO program can enhance production and, more importantly, keep everyone safe.
Jimi Michalscheck is the vice president and co-owner of ESC Services Inc., an engineering firm that specializes in lockout/tagout compliance. ESC has helped more than 250 companies around the United States achieve and maintain lockout/tagout compliance. To contact ESC, visit their website or call ESC directly at 262-939-4825.