As a worker reached inside the hopper of a meat mixer to remove stuck ground beef, the paddles that mix the beef rotated twice, nearly killing him. According to the California Occupational Safety and Health Administration (Cal/OSHA), which recently cited the employer and a temporary employment agency, neither business had properly trained the worker to de-energize the equipment before reaching in to unjam or clean it.

This employee was lucky to have sustained only a crushed hand, a broken arm, and nerve damage. A welder trying to remove a jammed piece of metal from the hydraulic door on a scrap metal shredder was less lucky. The system’s energy had not been released and the door had not been blocked open. The welder was crushed to death as a result.

Every year, between 150 and 200 fatalities and some 50,000 injuries occur due to failure to control the release of hazardous energy. Lockout/tagout (LOTO) refers to the OSHA-required practices and procedures to protect workers from unexpected start-up of machinery or hazardous energy released during service or maintenance. LOTO consistently appears on OSHA’s annual list of most-violated standards. OSHA maintains that compliance with the standard (29 CFR 1910.147) could prevent hundreds of deaths and thousands of injuries, including amputations, each year.

This article reviews the standard, hazards, and solutions offered by a world leader in automation and LOTO services.

Understanding the law and your duty under it

OSHA requires that equipment be locked or tagged out of service when there is a chance for injury. Workers may not attempt to operate switches, valves, or other controls once a device is locked or tagged. An authorized person must turn off and disconnect equipment from its energy source during service or maintenance.

Locks, tags, and other methods prevent those who are unauthorized from reenergizing equipment.  Lockout devices hold energy-isolating equipment in a safe or off position. They prevent equipment from becoming energized because no one can remove them without a key or other unlocking mechanism. Tagout items are prominent warning devices fastened to energy-isolating controls to warn employees not to reenergize the equipment. Tagout devices are easier to remove and, on their own, are considered less protective than lockout equipment.

The OSHA standard does not apply to work on cord- or plug-connected electric equipment and certain hot tapping operations. (Hot tapping refers to the installation of connections to pipelines while they are in service.) Minor servicing that takes place during production is also not covered, as long as the employer provides effective alternative protection from hazardous energy, such as guards.

In order to be exempted, minor servicing applies only to activities that are:

• Routine—part of  regular procedures
• Repetitive—repeated regularly as part of the production process or cycle
• Integral—inherent to and performed as part of the production process

Experts in automation

Rockwell Automation is a global leader in industrial automation and information. With annual sales in excess of $6 billion, the Milwaukee-based company helps customers in more than 80 countries achieve “smart, safe, sustainable operations in a wide range of industries throughout the world.” In October 2014, Rockwell Automation acquired ESC Services, Inc., a global provider of lockout/tagout services and solutions.

Experts from Rockwell Automation and ESC Services shared their knowledge about the state of the art in lockout/tagout.

Jimi Michalscheck is ESC Services director of market development; Steve Ludwig is program manager for safety at Rockwell Automation; and George Schuster is business development manager for Rockwell Automation.

Michalscheck says many employers misunderstand what businesses are covered by the standard. “Lockout/tagout applies to every industry, not just manufacturing,” he explains. “That includes hospitals, banks, casinos, and hotels. Any company that has more than 10 employees is required to comply.”

LOTO is as important in a hotel or government building as it is in a production facility. That’s because large nonmanufacturing buildings house dozens or even hundreds of pieces of equipment that can store energy—from air handler units on the roof to booster pumps, boilers, and other industrial equipment with high voltage and high hazards. Building owners and managers often fail to grasp the hazards and the requirements for compliance.

Another common misconception is that safety and productivity are incompatible priorities. That’s not the case, says Ludwig, who believes it is possible to have both without compromise. “Users of machinery no longer have to do a complete lockout under many circumstances—you can bring a machine to a safe state without completely shutting down.”

ESC Services helps organizations do this by conducting analyses and providing procedures that help them use their equipment in a safe, productive way that reduces both scheduled and unscheduled downtime. “Industry best practices are evolving quickly, and companies are realizing that LOTO is not a production killer unless you let it be,” notes Michalscheck.

By taking a close look at their overall LOTO safety program, companies can often reengineer processes to incorporate alternative protection measure procedures. These control the machine in a safe state and keep them in compliance. OSHA requires that alternative procedures do not introduce additional risk to employees.

“If you can design alternative procedures and an overall alternative program to ensure effective protection for specific tasks, then the sky is the limit to enhancing productivity,” Michalscheck adds. While it may be possible to engineer out many servicing activities with well-designed safety procedures and high-performance hardware, Rockwell Automation always recommends following LOTO regulations when servicing equipment where no “company approved” safe alternatives exist.

5 program elements

According to Michalscheck, there are five elements that should be part of an efficient and modern LOTO program:

• Corporate policy. LOTO policy describes enforcement protocol, includes guidance for on-site contractors, and details who has responsibility for correcting identified deficiencies.
• Machine-specific procedures. Rockwell Automation and ESC Services recommend creating graphical, machine-specific procedures for every piece of equipment in the facility and installing procedures at the appropriate point of use.
• Training. Compliant and effective training targets authorized personnel, affected employees, and contractors, with specific modules customized to each group’s needs.
• Locks and devices. Locks and devices should be specific for lockout/tagout and uniform in make and color. This discourages employees from using them for other purposes, such as locking their toolboxes, which can lead to an OSHA citation.
• Annual audits. Every procedure must be reviewed, and authorized employees must be audited annually to ensure program integrity. Maintain all findings from the audits as proof that your program is compliant in the event of an OSHA inspection.

A well-designed and executed program based on these elements can increase production efficiency by delivering:

• Reduced lockout time during routine, scheduled, or unplanned maintenance by an average of 50 percent or more.
• Reduced unlock time after maintenance by an average of 50 percent or more.
• Prevention of delayed starts. Lack of communication between authorized employees and operators leads to idle equipment. Hours of downtime can result when equipment repairs are complete, but the message is not conveyed to operators.
• Prediction of inefficiency trends. Trend identification is improved with data collection tools that track minimum, maximum, and average lockouts per machine and per authorized employee. If a trend emerges, it’s easy to see and address.
• Accident reduction. Accidents lead to downtime, regardless of whether an injury is involved. Supported by proper lockout/tagout policy, procedures, and training, operators and authorized employees are less likely to have an accident.

ESC Services also offers advanced tools, including a software application that includes open source MS Excel® files, a website portal for housing the files, and a tablet for scanning a QR code on the procedures for quick access.

A better, more-efficient mousetrap

A printing company found that replacing antiquated, text-based procedures with new graphical procedures considerably cut the time required for authorized employees to identify breakers for remote disconnects. Lockouts for even simple equipment like conveyors that did not previously have written procedures were reduced from 1 hour to 5 minutes with the new system. For more complex equipment, like a printing press, a 4.5-hour lockout procedure was shortened to 30 minutes and employees had more confidence that it was performed correctly.

Using downloadable Excel files made it easier and quicker to identify and make changes to procedures. And an iPad® application that syncs with the employer’s secure website portal substantially reduced the time needed to audit hundreds of procedures over a 12-month period.

Taking it to the next level

George Schuster explains that LOTO can actually boost rather than diminish productivity. He points to the long tradition of optimizing manufacturing tasks to make them faster, easier, and more productive. Until fairly recently, however, that same approach had not been applied to equipment maintenance.

“There’s a growing recognition that lockout tagout and other processes to make machinery safer are all part of the overall productivity of a plant,” says Schuster.  Applying the same keen eye to maintenance reflects a more holistic view of manufacturing.

If a machine is down due to a jam, failure, or other reason, getting the maintenance performed quickly and safely presents another opportunity for optimizing productivity. The key is to ensure that the equipment can be shut down and LOTO performed and verified in an efficient and orderly fashion. Strategies like making sure carts are supplied with needed tools and parts contribute to more expeditious restarting and less lost productivity. “Downtime events are being broken down into smaller slices, and each slice is being scrutinized for optimization,” Schuster adds.

Why do LOTO incidents persist?

Despite new approaches and improved systems, lockout/tagout-related incidents are not diminishing, and in recent years have risen. According to Schuster, “LOTO is sometimes so poorly engineered and so poorly integrated into the rest of the machine function that it is bypassed.”

Michalscheck concurs and also notes the many “incentives” for bypassing LOTO procedures. For example, a worker in a hospital setting might take a shortcut because he is concerned about being able to complete a maintenance task in the time allowed on the work order. Michalscheck warns that such “false finish lines” can contribute to incidents and inefficiency and offers the following example:

A work order allows 35 minutes for changing a belt on an exhaust fan, and the maintenance employee feels pressure to stay on schedule. If the employee has the parts and knows how to lock out the fan, 35 minutes may be sufficient, says Michalscheck. But if the employee approaches the task and realizes he or she does not know the procedure, the temptation might be to bypass lockout altogether rather than conduct the necessary research to do it properly.

In a different type of work environment, such as a manufacturing plant, production pressures may be the reason the employee fails to lock or tag out the equipment before performing service or maintenance.

Consider a case packer that jams repeatedly. An employee knows how to lock out the equipment but might be unaware that lockout may not be the most efficient safe procedure for unjamming this particular machine. If the packer jams three times in an hour and cutting all energy sources takes 7 or 8 minutes each time, an alternative and compliant method (such as remotely operated tools or guarding with redundancy and verification) could cut that down time to 30 seconds per jam.

Ludwig says one reason incidents occur is because employers fail to understand alternative protective measures and the requirement that they not add risk to the procedure. “Understanding the procedures and technologies you are working with is a vital skill set,” he adds. “You can’t assume that because you unjam something multiple times you can do it without LOTO and call it an alternative method.”

Training: Talk about why it matters

In some cases, incidents are a result of poor or improper training, such as failure to customize the training to the industry or failure to involve hands-on demonstration or proof of competency. Says Schuster, “A good system is a combination of technology, systems, and people who are trained and understand how to use it.”

Despite OSHA’s requirement that a LOTO-authorized employee need only be trained once (except in cases of job reassignment or new equipment), Rockwell Automation advises clients to train at least annually. The training should be dynamic. That is, it should not be a rehash of the past year’s training but should include new content and fresh perspective. Review near misses and equipment pain points (like the machine that jams three times in one-half hour). Go beyond discussing how to perform lockout/tagout, and address why it matters to your business.

Also be aware of the requirement to train contractors—a frequently overlooked mandate. While contract employees may not need to know every detail about your system, they do need to be trained and authorized just like your own employees. This can be accomplished in a relatively quick, on-the-floor session focused on the actual equipment employees will be encountering.

Schuster advises safety professionals to “Consider holistically the way people interact with machinery. If you do it in a piecemeal manner you’re going to miss the most critical, systematic aspects of a comprehensive compliance/safety approach, including the people, the culture, management support, and other elements of what we describe as a company’s ‘safety maturity.’”

Best-in-class companies go beyond considering lockout/tagout as solely a compliance issue. Done right, it can actually drive productivity.

Rockwell and ESC offer additional perspectives on lockout/tagout issues at www.escservices.com/learning-center.