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Prevent LOTO Mistakes with Visual Communication

Brian McFadden, Contributor

One of the often-overlooked requirements in OSHA’s LOTO regulation is that the locks, tags or other equipment used for LOTO must be clearly identifiable and traceable to the specific individual who applied them.

Effective Lockout/Tagout (LOTO) systems protect workers from unexpected movement or energy release during equipment service. OSHA estimates that these procedures save 120 lives, and prevent 50,000 injuries, every year.

Naturally, any workplace that takes worker safety seriously will work hard to maintain an effective LOTO program. But we’re all only human; mistakes still happen. With care, though, we can take steps to prevent those mistakes. In many cases, visual signals are the key.

Identify Possible Failure Points

Before you can solve a problem, you need to understand what that problem really is. What might go wrong in your LOTO process?

You may already know where LOTO systems have failed in the past in your workplace; injuries and even fatalities may have occurred. You may have had near-misses, where workers managed to avoid harm even though the LOTO process didn’t work correctly. These past events offer insight into what might happen in the future.

If your workplace has been fortunate so far, you may not have these data points available to learn from. Instead, you’ll need to rely on a close understanding of the equipment in your facility, the maintenance and service procedures that are called for and the LOTO program that is already in place. Few individuals will have all that expertise; instead of relying on one person to know everything, take advantage of the collected knowledge of your team.

Ask for ideas and suggestions as part of reviewing your LOTO program. Every time a work process changes, consider if the LOTO procedures need to be changed as well. Revising a plan to account for new information does not mean the plan was a failure—especially if reviewing and revising the plan was part of the plan in the first place, as required for OSHA-compliant LOTO programs!

Post Equipment-Specific Procedures

Once a procedure has been created for a given piece of equipment, that plan needs to be put into action. Authorized employees, who are the workers assigned to perform LOTO in each situation, should have clear training on the steps to be taken in their work.

With appropriate training, any of these authorized employees should be able to explain the core concepts of LOTO and make reasonable guesses about the steps for a given task. But it’s unlikely that any one worker will memorize the exact steps for every machine, and even more unlikely that they will be able to recall each step correctly every time, without ever making a mistake. All it takes is one mistake, happening one time, to cause serious injury or death; that’s why LOTO exists in the first place.

Why rely on guesses or fuzzy memory, when your LOTO program already includes written step-by-step instructions? It’s easy to create a label or sign that lists the steps for a specific machine. Posting that sign right on the equipment will provide your workers with the information they need, in the time and place they need it. These procedure labels serve double duty: they remind workers that LOTO is necessary for specific service needs, and they provide a “checklist” to ensure that steps aren’t forgotten.

Mark Key LOTO Locations

One of the common uses of facility signage is to help people find their way around, with directional signs and floor marking. (This kind of visual signal is usually called “wayfinding.”) Effective wayfinding saves time by helping people quickly understand and navigate their surroundings. Applying the concept of wayfinding to the needs of a LOTO program can help improve safety and efficiency there, as well.

Typically, a specific switch, valve or breaker will be the designated shutoff point for a given LOTO procedure. How quickly can the authorized workers locate the right switch? Marking it with a label will help speed the process along.

Should there be a lock at a given location before maintenance work begins? If there’s a sign saying so, anyone walking past that sign will be able to check for the lock, and essentially become part of a double-checking system to make sure the life-saving procedures are being followed.

Identify LOTO Equipment

Some of the often-overlooked requirements in OSHA’s LOTO regulation are that the locks, tags or other equipment used for LOTO must be clearly identifiable, must be used only for LOTO processes and must be traceable to the specific individual who applied them.

The most reliable way to meet these goals is to ensure that every authorized worker has a lock marked with “LOTO” and their name. If that lock is in place, keeping a piece of equipment disconnected from a power source, only that person should remove it. Separate tags are often used instead, with a large and eye-catching warning about why the lock is there, and additional details (such as names, dates or contact information) added by hand or with on-demand printing.

When a workplace uses only a limited number of locks and doesn’t assign them permanently to individual employees, it becomes even more important to use visual signals effectively. In those cases, the tags become the only connection linking a given lock and the worker whose life it protects. Handwritten details that become smudged or illegible simply won’t provide effective protection.

It’s important to maintain good communication about all the parts of a LOTO program, whether on the LOTO devices themselves, on the equipment to be locked out or in the facility in general. Visual signals like signs and labels can provide reliable avenues for that communication. WMHS

Brian McFadden is a Compliance Specialist and writes for Graphic Products, makers of the DuraLabel line of industrial label and sign printers (www.GraphicProducts.com).

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