Take a Deep Dive into Your Lockout/Tagout Program with Rockford Systems Gap Analysis

As the name implies, LOTO Gap Analysis seeks to identify the “gap” between where a company’s lock-out/tagout program currently stands and where it needs to be as defined by OSHA 1910.147 (The Control of Hazardous Energy), as well as by industry best practices. By analyzing identified gaps, the safety team gains insights into the health level of the LOTO program. Analysis can also help determine if employees understand and are correctly implementing LOTO procedures. Most importantly, by exposing both the weaknesses and strengths of the LOTO program, a gap analysis can lay the groundwork for establishing an action plan to achieve world-class safety excellence.

In this blog, we’ll give you an overview of how LOTO gap analysis is performed by Rockford Systems. Our data collection and analysis will help determine if your company’s LOTO program is on the right track. In addition, it will present measurable goals our team can support you in reaching by taking a more proactive, continuous improvement approach to Lockout/Tagout safety.

Many times, it takes a serious accident or a near miss to uncover LOTO program deficiencies, and by then it’s too late. That is why the time to act is now. LOTO Gap Analysis can be a key tool in your company’s toolbox, bringing to light any shortfalls in safety operations today, while promoting long-term resiliency into employee preparedness, and creating value by reducing accidents and eliminating costly OSHA fines.

ANNUAL AUDIT VS. GAP ANALYSIS

First off, we should explain that conducting gap analysis is very different than performing the periodic inspections that OSHA requires annually of your equipment specific procedures. The periodic inspection strictly acts as confirmation that an organization is following 1910.147. Typically, these inspections are done by an in-house team who reviews the written energy-control procedures and how effectively the authorized workforce is applying these procedures. Periodic inspections are very important to ensure procedures are accurate and that employees understand their responsibilities and are applying LOTO accurately. But this is only looking at one element of the LOTO Program.

In contrast, gap analysis is a deep dive into a LOTO program. It is a far more detailed benchmarking of its performance at a given moment in time, concentrating on defining its deficiencies and implementing change to close any gaps identified in the analysis. From a real-world perspective, gap analysis is more likely to detect a potential hazard than an annual audit, although both are critical to the success of a LOTO program.

In gap analysis, a company must make specific, measurable goals to yield the greatest long-term success. For example, it would do a company little good to set the goal of “being a safer organization.” Instead, a company must identify more trackable metrics, such as “meet or exceed 1920.147 requirements within three months in our two manufacturing plants.”

HOW WE WORK

As mentioned earlier, a gap analysis starts by focusing on where your organization’s LOTO program is currently operating at. To determine that, Rockford Systems carefully assesses three targeted areas:

1. Compliance: Our team will go on-site to your facility to review compliance by fully assessing your existing LOTO program per 1910.147 OSHA, as well as if it meets established industry best practices, including all existing documents and processes. Key stakeholders in your organization will need to provide evidence that they have met OSHA requirements. Some examples include ensuring the energy control procedures exist and include all the required elements, that periodic inspection certifications are current, that training material is sufficient and training records are current, and that protective material and hardware is available and sufficient for the type of equipment etc.

2. Application Next, our team will visually review your authorized workforce while they are actively performing a task on every machine in your plant that requires lockout tagout. Observing your workers conducting the procedures, photographing them in action, and analyzing each step they take is the only way to truly determine if the program elements are appropriately being applied in the field.

3. Understanding: Finally, a representative sampling of your authorized workforce will be interviewed to accurately gauge the depth of their understanding of 1910.147 OSHA processes. Interviews and written surveys delve deep into your employees’ comprehension of their assigned responsibilities on each machine they are responsible for. Interviews are conducted anonymously to encourage free expression.

Focusing on all three areas provides a full understanding of what’s “really” happening with your LOTO program. For instance, you could have a well-defined shift change process in your program, but it’s not being applied in the field. This could be caused by a total lack of understanding by the authorized workforce or a lack of implementation and enforcement. This Gap Analysis will uncover any gap whether it’s documentation, how it’s being applied, or the level of understanding the authorized work force has.

Our gap analysis system is scored with a numerical rating ranging from 0 (“no evidence of compliance, application or understanding”) to 4 (“exceeds compliance, application, or understanding”). A number is assigned to each of the three areas above, culminating in an overall performance result for your organization. As the adage goes, “you can’t manage what you can’t measure.” Rockford System gap analysis gives you a quantitative means to truly measure your LOTO program and to better understand what barriers are preventing safety goals from being met.

Once complete, a compilation report will be issued by Rockford Systems that identifies specific areas in need of improvement and outlines an action plan to achieve increased company performance. Each item within the three categories that demonstrated a “gap” — identified by a score of 2 or lower — is presented with a recommendation to meet regulatory compliance needs. Recommendations can include additional training for employees, an updating of written policies, implementing a group LOTO process, recommending locks and devices, developing/updating equipment specific procedures, or whatever it takes to put your LOTO safety program on the right track to prevent injuries, reduce machine downtime, eliminate OSHA fines, and maximize company resources.

CONCLUSION

One of the drawbacks often cited of OSHA 1910.147 is that it tells us what steps need to be taken to be in compliance, but not how to ensure those steps are actively being applied in the field. That’s where gap analysis proves its value, time and again. Gap analysis is a circular process where after the initial action plan has been rolled out, the company will need to reevaluate its position as it strives for continuous improvement. As long as manufacturing continues to evolve so will the need for safety programs to keep pace.

As a highly experienced, non-biased third party, Rockford System is the ideal choice for your LOTO gap analysis. Our trained professionals will not only thoroughly evaluate your LOTO safety program but help prevent accidents and fines in the future with solutions that will leave your operations safer and your workers more proficient.

Contact us Rockford Systems at 800-922-7533.