By: Brian McFadden, Contributor
Many warehousing operations use motorized equipment, like conveyor systems, to maintain efficient workflows. Some workplaces have more specialized needs, like industrial refrigeration systems for cold-storage facilities. Larger workplaces often call for more powerful equipment. As long as guards remain in place and workers follow safe practices, these systems can be relatively safe.
But when maintenance is called for, guards may need to be removed, and workers may need to access areas that would be dangerous if the machines were running. Workers need a way to ensure the equipment doesn’t start up or move while their hands are still in the gears. The best approach for this is lockout/tagout LOTO. OSHA also calls this process “the control of hazardous energy” in its relevant regulations, found in 29 CFR §1910.147.
As long as they’re used correctly, LOTO procedures offer unparalleled protection. Unfortunately, that can be a major weakness: human error is a hard pitfall to avoid. Preventing human error often comes down to a question of training, and LOTO is no different. For the procedures to be effective, workers need to be trained on the steps and the reasoning behind them.
Tailored Training for Actual Needs
Even within a given facility, different workers will need different kinds of training. Fortunately, there are three general categories of workers when it comes to LOTO procedures; it’s easy to identify which category a given worker falls into, and it’s easy to adjust the training provided to workers in a given category to match their needs. These categories are even written into OSHA’s regulations for LOTO training, so the terms and requirements are consistent across all American workplaces.
“Authorized workers” are those who will actually perform the work that needs to be protected by LOTO procedures, which means they’re the ones who will follow those LOTO procedures as well. Naturally, these workers will need the most detailed training.
This training starts with general concepts, ensuring the workers will recognize the potential hazards that LOTO is meant to protect them from. Then, it will get more specific, helping them understand the steps needed to identify, isolate and control those hazards effectively.
Finally, the real-world steps for LOTO on each piece of equipment will be provided. To be effective, these steps may need to be customized for each machine or each service process. At the same time, it’s unlikely that any one worker will need to know the steps for every machine; each worker only needs to know the specific steps they will actually need to follow. The division of work in your facility will affect how much cross-training is valuable.
Affected Workers and Others
Authorized workers are most directly involved in LOTO, but they aren’t the only ones who need LOTO training. There are two other categories of workers who will need more general training to ensure that the LOTO processes are respected.
“Affected workers” are those who don’t need to perform those dangerous maintenance tasks, but whose normal work may be interrupted by having equipment locked and tagged out. These workers don’t need to learn the step-by-step procedures for tasks they’ll never perform. But they will definitely need to know what lockout/tagout means and why it matters; how to recognize what LOTO will look like on the equipment they normally use; and what they should do while that equipment isn’t available.
The last category, “other workers”, will be generally unaffected by the use of LOTO; they won’t need to change their behavior in response to those procedures. As a result, they simply need to understand what LOTO means, how to recognize when it’s being used and why they should never attempt to bypass a lock or tag to start up equipment.
The Most Important Point
In any workplace where LOTO is used, those procedures represent a barrier protecting workers from severe injuries and even death. The most important part of LOTO training is this: all workers must be prohibited from removing other workers’ tags or locks or attempting to start up equipment that other workers have locked or tagged out. If one employee applies a lock, but another employee removes it and starts the equipment, what was the point of the lock? It may seem obvious but leaving any confusion about this point can eliminate any protection offered by your LOTO procedures.
Many of OSHA’s rules about LOTO are meant to make this key element as clear as possible. Locks and tags must be standardized and recognizable, for example, and that will reduce confusion. They should also be substantial enough that conscious effort is needed to remove them; if a lock or tag could come off by accident, you need better locks and tags.
Another common practice is to identify the points where locks or tags should be applied with a marker or label that draws attention to the area. If a lock is present there, workers will immediately know that LOTO is being used, and they should not attempt to start the equipment. These labels may even include the appropriate steps to lock out the equipment they’re posted on, providing a handy checklist to further reduce the chance for human error.
LOTO fits into the overall Hierarchy of Controls as an important tool in keeping workers safe from workplace hazards. This hierarchy starts with eliminating the hazard wherever possible; if that’s not possible, less-effective controls are applied, progressing down the hierarchy until the risks are acceptable. Ultimately, LOTO is an Administrative Control, a work process that alters worker behavior in the face of a hazard. Administrative Controls are low in the hierarchy because they rely on people not making mistakes. Training is critical in getting the most protection from these kinds of controls. WMHS
Brian McFadden is a Compliance Specialist and Technical Writer for Graphic Products, the makers of the DuraLabel line of industrial label and sign printers. For more information about customized visual communication, visit www.GraphicProducts.com or call 800-788-5572.