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Proper Lockout/Tagout Procedures Keep Employees Safe and Ensure Safety Compliance – Part II To reduce the risk of fines and minimize the effect on the workforce, many employers find it beneficial to outsource the job of developing and implementing their lockout/tagout program to a neutral third-party contractor. This can dramatically decrease the amount of time needed to implement a thorough, OSHA-compliant lockout/tagout program. The associated costs in working with a qualified contractor on your program typically provides a significant return on investment in terms of increased productivity and fast, effective compliance. If the decision is made to create the lockout/tagout procedures in-house, then pay special attention to the common mistakes often made by employers that could result in citations and fines from OSHA. Generic procedures. One common mistake is creating procedures that are too general. OSHA requires that a specific procedure be written for each piece of equipment. The only exception is if one lockout/tagout procedure adequately addresses all unexpected energization hazards related to each machine. If you have similar pieces of equipment, take precautions not to fall into the trap of printing the procedure multiple times and believing your program is in compliance – it may not be. Two identical pieces of equipment may be used and installed differently, therefore requiring distinctly separate procedures. Complex procedures. Another common mistake is making the procedures too complex. The safety and protection of employees depends on these procedures, which could be jeopardized if they cannot understand the procedures or be able to use them in an emergency situation. The use of graphical lockout procedures can alleviate this common mistake. Correct selection and use of lockout/tagout products. Lockout/tagout ensures employee protection while performing service, maintenance and other activities on equipment. However, lockout/tagout is seriously compromised when more than one employee is working under the same lockout/tagout device. Note that if a machine has already been locked out and another employee needs to work on that machine, the employee must place a personal lock on the machine that is designated for lockout/tagout only and maintain exclusive ownership of the key. To avoid misuse of lockout locks and tags, perform regular lockout audits, and use uniquely keyed locks that come with only one key. Lockout/tagout devices must be standardized, and must not be used for any other purpose. When undertaking a comprehensive lockout/tagout program, whether through an experienced third party contractor or internally, it is important to be familiar with the steps and potential pitfalls that could affect your program. Properly executed and maintained, your lockout/tagout program can provide substantial returns in terms of improved productivity. And, your lockout/tagout program can help your site achieve VPPPA’s Star rating and ensure both OSHA compliance and, more importantly, employee safety. Sheree’ Evans-Metcalf was the Technical Trainer for Molson-Coors at the Golden Brewery Packaging Division in Golden, Colorado. Sheree’ worked for the Coors Brewing Company for 33 years. She retired in 2007 and is now a facilitator for the PMMI Certified Trainer Program. |
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