The Dangers of Complacency in Lockout-Tagout Program Management

It has been said that “Success breeds complacency. Complacency breeds failure.” Complacency in a lockout-tagout (LOTO) program doesn’t simply breed failure — it breeds danger. When weeks of accident-free operations become months or even years, complacency sets in. Safety departments begin to believe that LOTO can be put on the backburner. But that’s when accidents tend to happen. Accidents, injuries and deaths attributed to LOTO failures are on the rise. In 2022, “Control of Hazardous Energy” was the sixth most cited safety violation by OSHA. OSHA issued 1,977 LOTO citations in 2022 compared to 1,698 citations in 2021.

There are a number of ideas that try to explain the recent rise in LOTO-related incidents. One worth noting is employee age. The average age of a manufacturing worker in the United States stands at 38 years old. Statistics show that worker accidents begin to rise at the age of 35 when cognitive, vision, reaction time, hearing and memory begin to decline. The average age of maintenance workers tends to be a bit higher due to the experience needed to perform complex repairs. For instance, the average age for a plant electrician is 47. The average age for mill workers is 42.

Age is an important factor to keep track of since baby boomers are working longer before retiring. On the other side of the coin, when older workers do retire, they take with them critical skillsets that increase the likelihood of a LOTO-related accident occurring. Also, an increasingly multi-lingual workforce that may struggle with LOTO procedures written only in English can lead to accidents. Yet another explanation is the higher technology incorporated into new machines that add to the complexity of their maintenance. Unfortunately, a dramatic surge in opioid use has also been cited as a possible factor.

As compelling as those reasons may sound, it is complacency that remains the greatest threat to a LOTO program’s effectiveness. In fact, it’s the reasons listed above that underscore why we can’t be complacent with LOTO. Complacency tells us everything is fine. Complacency prevents us from seeing gaps in a LOTO program that an OSHA inspector could drive a truck through.

If you have grown a little too comfortable with your LOTO program, allow us to make you uncomfortable. There are gaps in your program. Large or small, they are there. But where are they? In all probability the answers can be found in OSHA statistics. Below are the four most cited LOTO violations of 2022. After reviewing, take an honest assessment of your LOTO program. Could it possibly violate these requirements, too?

  1. No documented program.
  2. No updating of procedures.
  3. Lack of employee training.
  4. Lack of periodic inspections.
  1. NO DOCUMENTED PROGRAM

The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry states “procedures shall be developed, documented and utilized for the control of potentially hazardous energy.” Procedures must be company, site and equipment specific and aligned with operational practices, or as OSHA explains “specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy.”

Virtually every piece of equipment on your plant floor must have its own documented LOTO procedures. Documentation must be posted on or near the machine meant to be locked out. Increasingly, companies are augmenting their written documentation by posting procedures online where password-protected instructions can be easily accessed on the authorized employee’s smartphone or tablet.

Here is some of the information required on each machine’s documentation. You can find document examples on OSHA’s website or you can contact Rockford Systems for samples.

  1. Equipment name and location on the plant floor. Documentation may also feature an asset part number that the equipment was assigned by the company’s maintenance team.
  2. Name(s) of the employees authorized to perform LOTO procedures and their responsibilities.
  3. Any unique hazards of the machine.
  4. All energy source types needed to be isolated — electrical, mechanical, thermal, chemical, et cetera. All must be rated by magnitude with their locations pinpointed, along with the number and types of locks required for each to reach a zero-energy state.
  5. Procedures to dissipate or release any stored energy, if required.
  6. Procedures for tagout of the energy isolating device.
  7. Verification steps, such as checking gauges or testing with meters.
  8. Procedures for re-energizing machinery when maintenance is complete.

It is considered best practices to use photos and diagrams to more thoroughly describe each step involved in safely “shutting down, isolating, blocking and securing machines or equipment to control hazardous energy”. If procedures are posted online, video is an excellent guide. In a multi-lingual workplace the procedures should be in every language that employees use.

If you need to develop procedures, it will require a partnership between the safety department and the maintenance crew. Chances are, no other employees in the company know machinery better than those who maintain and repair it regularly. Once you have authored a draft, have it reviewed by all parties — safety department, maintenance team, authorized employees — to identify any hazards you may have missed. After approved, test the procedures on the machine to verify a zero-energy state, and then move onto training all authorized and affected employees.

Sound daunting? Rockford Systems has created LOTO procedures for virtually every type of manufacturing machinery. Contact us to discover how easy, cost-effective and fast we can make LOTO document development for your organization.

  • NO UPDATING OF PROCEDURES

Factories are always in a state of flux. New machines are added while others are retired. Machines are moved from one department to the next. Processes are changed to accommodate new production needs. Modifications are made requiring different power sources.

Every change to your machinery inventory must be accompanied by a similar change to LOTO documentation. It is highly unlikely that the LOTO for an old hydraulic press will be identical to the LOTO for the new state-of-the-art press that’s replacing it. New machines bring new dangers.

OSHA requires a review “whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed.” 

  • LACK OF PERIODIC INSPECTIONS

At least once a year an authorized employee — who is not the equipment operator — must conduct an inspection of the energy control procedure to ensure the 1910.147 standard is being followed. According to OSHA, these inspections are meant to “correct any deviations or inadequacies identified.” Employers certify the inspection was performed, specifying which machines were tested, the date(s) of the inspection, the employees involved, and the person or company performing the inspection.

Unfortunately, inspections take time that you rarely have and may seem unwarranted when no accidents have occurred. That’s why Rockford Systems has a team of professionals that is readily available to conduct onsite inspections of your LOTO procedures with full certification, along with testing your machine safeguarding systems. Call us to schedule.

  • LACK OF TRAINING

It is not enough to have a written program. Your LOTO procedures must be fully understood by the workforce and followed as directed. That requires training and communication “to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees,” per 1910.147.

Employees learn differently. LOTO training can be performed with hands-on demonstrations, classroom sessions, or on the Internet. Classroom instruction is excellent for encouraging discussions, while demonstrations are needed to learn the how to operate LOTO devices. New hires must be trained before they are allowed into a hazardous area. Further training is strongly encouraged for all authorized employees, at least annually.

When does an employee need immediate training? Here’s a guide:

  • They admit or demonstrate that they don’t understand processes.
  • They are involved in an accident.
  • They move to new department.
  • Modifications are made to the equipment they operate.
  • Periodic inspections identify gaps in their behavior.

Also, contractors that the plant hires to conduct maintenance or repairs on machinery will need to be trained by your safety department, and learn to follow the same procedures that your authorized employees do. Training outside contractors alongside your authorized employees is considered best practices.

FINAL WORDS

We started with a quote about complacency, so we’ll end with another: “If it ain’t broke, don’t fix it’ is the slogan of the complacent, the arrogant or the scared.” (Colin Powell)

Complacency has no place in lockout-tagout management. Prevention of workplace injuries is a never-ending challenge. Rockford Systems is here to help you meet that challenge, today and tomorrow. Contact our team for more information at 1-800-922-7533.