-By Thomas G. Dolar
Reprinted with permission from Facility
Safety Management Magazine
At first glance it might appear that Lock Out/Tag Out is
a relatively easy safety measure to enforce. Lock Out refers
simply to locking access to a hazardous machine and/or space.
Tag Out is a lesser measure that implies a sign, which provides
a specific directive that a certain area or machine is dangerous
and should be avoided without authorization. Sometimes the
two are needed separately. Other times they are used in
concert.
Although
Lock Out/Tag Out, as a concept, is straightforward and easy
to understand, its implementation is often not quite so
simple. “Lock Out/Tag Out is
a national program of OSHA, and one of its primary concerns,”
says safety consultant Sam Church, managing director, Safety
Department, Inc., Pittsburg, PA.
Church offers a number of reasons why Lock Out/Tag Out
regulations are not
always as adhered to as closely as they should be. “From
my perspective, I see many facilities that tend to use a
cookie-cutter approach to compliance for Lock Out/Tag Out,
which falls far short of the high degree of specificity
that OSHA requires,” Church says. “I
believe some employers may confuse the allowance OSHA writes
in for identical equipment.”
Church explains that if one machine is exactly identical
to the next and is in
the same location, then the procedures may be identical.
However, if there are any changes or customization to a
machine and/or the machines are in different locations,
this necessitates highly detailed written procedures for
each. Each must have a separate Lock Out/Tag Out set of
rules and paperwork.
| Can
computerized training do an efficient job in terms
of Lock Out/Tag Out? |
| One
man who answers in the affirmative is Kirk Berry,
vice president, sales for Mastery Technologies,
Inc., Plano, TX. The company produces 100 safety
videos, which are delivered from a computer, whether
internet, Web, or CD-based. Two of these are devoted
to Lock Out/Tag Out. They differ somewhat, for
one is aimed at the affected employees and the
other the authorized employees. The test usually
takes about 30 minutes for affected employees
and 45 minutes for the authorized. “Whenever
the student missed a question, he is taken back
to review that material,’” Berry says.
“So he’ll keep reviewing it until he
achieves a 100 percent score.”
Whereas traditional
classroom teaching tends to miss or gloss over
certain points, this method is much more thorough.
“Typically our students achieve a 300 percent
mastery over the traditional way,” Berry
says. “And the same material can be taught
in half the time, at a time of the student’s
convenience.”
|
|
“Another glaring shortcoming
is the failure of employees to audit their own programs,”
Church continues. “There’s
a tendency to get everything down in writing, and then put
the document on the shelf. But there must be a constant
effort to observe procedures in the real world, and make
sure they are being followed.”
Church adds that OSHA uses the term “periodic” and
managers often tend to audit their procedures on a less periodic
basis than should be. Generally, Church says, the larger the
facility, the more frequent should be the audits.
A third area of common negligence, Church says, is the
annual review. “Every year management
should sit down and go through all the procedures,”
he says. “If anything has changed,
the written instructions should be updated. Even if nothing
has changed, a thorough review should take place, and it
should be documented."
Church points out that Lock-Out/Tag-0ut is generally referred
to protect against the release of any type of stored energy,
including electrical, chemical, radioactive, pneumatic and
hydraulic. But he says what is often overlooked are motor
vehicles. In routine maintenance there should be procedures
to make sure the vehicle does not start accidentally and
that the wheels are locked. “Gravity
also serves as stored energy, as when a forklift holds something
in the air,” says Church. “Gravity
is a stored energy at play also in situations where you
have gas in elevated holding tanks.”
Lock Out is always preferred to Tag Out by safety professionals,
Church says. But he adds that some situations are virtually
impossible to Lock Out, so OSHA provides Tag Out options
in various situations.
When asked the most frequent failure in this area, Church
replies, “When someone enters
an area, turns off a piece of equipment, then walks behind
it. A co-worker comes in, sees the equipment is off, and
then turns it on, exposing the first person to hazard. This
happens all the time. Workers tend to want to take short
cuts. Here the first worker was entirely at fault. He should
have locked the door, then put a tag on the machine as well
saying, 'Do Not Touch'.”
The problem, Church says, is that often, as in the case
above, the worker is taking a short cut not so much because
he is lazy, but because he is trying to do a good job, and
does not want to slow productivity.
Another frequent violation, Church says, is actively circumventing
a machine safety interlock. “The
most tragic incident that I have personal knowledge of in
this regard was an employee of a recycling company who came
to work early one morning at 4 a.m.,” Church
says. “He was an experienced
driver, and was coming in on his own time, because, after
10 or 12 years operating in rainy weather, he knew wet newspaper
could settle on the bottom and jam up the blade. The best
we can figure in reconstructing what happened is that he
lifted the two interlocking doors built into the equipment
for protection, then placed two bolts on them, which would
simulate their being closed. “
"Usually a cleaning process
like this would take two men. But we think he circumvented
the interlocking device and used a long handled ice chipper
to try to get under the newspapers while the blade was in
motion. The blade caught him. He was not crushed, but asphyxiated,
as if from a boa constrictor. He was a good employee, who
came to work early on his own time to solve a problem.”
Lock Out/Tag Out injuries occur because employees do not
recognize the hazard, assume they understand it when they
really do not, or get into the habit of taking short cuts
which they have gotten away with before, said Jerry Hartt,
a safety consultant, whose Hartt Safety Services is based
in Baton Rouge, LA.
Hartt speaks of one petrochemical plant he began working
for about six years ago after an incident in which two men
from an aerial lift were injured. This necessitated a review
of all of the company's safety procedures. “Since
then we've had a really good track record,”
he says.
He explains that the company goes beyond the OSHA safety
permit to make the procedures even more stringent, and a
paper trail is maintained throughout the entire process,
along with multiple checks.
For instance, the locks on the electrical circuit breakers
are checked and documented by the operator, then verified
by the front line supervisor, and, if there is a third party
contractor or subcontractor, by that person too. “Then
comes the safety department to provide further verification,”
Hartt says. “There are a lot
of checks and balances and the safety department acts like
a set of inspectors."
The 400 employee plants makes food grade plastic, such
as that used in milk jugs. “We’re
always running tests on the plastics, to make sure they
are safe for the consumer,” Hartt says. “In
the same way we’re constantly checking the work site
to make sure things are safe for the worker. Our motto is,
‘We inspect what we expect.’”
Although there have been no failures in the six years since
the program began, the company is not complacent. “When
we catch any little thing, like a form not filled out correctly,
we remedy that, and reinforce the correct behavior. Some
issues are immediately addressed by the safety manager to
the worker. If there is a repeat or a trend, the matter
is taken to the supervisor for reinforcement. It is a continual
process of behavior modification.”
