After almost 12 years of information gathering, studies, public comments and reviews, in 1989 the US Occupational Safety and Health Administration (OSHA) issued its final Control of Hazardous Energy (Lockout Tagout) Standard. Since that time, there has been significant improvement in the number of equipment-related serious injuries and fatalities. In fact, OSHA believes that implementation of the standard has led to 85% fewer injuries caused by working with hazardous energy. That’s quite a success story.
For some companies, however, implementation has been a challenge. US workers still suffer more than 20 amputations every day, and Lockout Tagout continues to be positioned in the list of the Top 10 Most violated OSHA Standards. In fact, as shown in the chart below, it’s been in the Top 5 for 9 of the last 13 years. Why?
So how do we counteract these problems? It begins with evaluating the equipment itself. Pull together a team of engineers, technicians, operators and mechanics and conduct a risk assessment on each piece of equipment or system in the plant. The team must be familiar with the equipment being evaluated, so you may need a different team for each individual work area. It’s very important that the team members know how the equipment functions, how it must be operated and the maintenance and service tasks that are required (including adjustment and set-up).
If we all know the benefits of using lockout tagout to protect the worker, why do companies still struggle with compliance? The reality of the situation is that implementation of the lockout tagout standard is still viewed by some managers and employees as burdensome and time consuming. Production levels suffer when the equipment is shut down for repair and trouble-shooting is almost impossible, since energy sources must be active in order to make observations. In today’s automated production lines, machine interventions may occur multiple times per day – to clear jams, re-calibrate sensors, troubleshoot minor problems, etc. Employees who are focused on doing “whatever it takes” to keep machines running are tempted to take shortcuts – especially those that have worked well for them in the past. In most cases, these employees have never suffered a major machine-related injury so they believe “it will never happen to me,” and are more likely to continue the practice.
The team must identify and rank the risks involved with every single activity. For those activities that require exposure to hazardous energies, the team should ask two essential questions:
1. Is the activity “routine, repetitive and integral to the production process?” The definition of this work is very specific under the OSHA Lockout Tagout standard. If the activity meets this definition, it’s likely you may apply the “Minor Servicing Exception.” If the “Minor Servicing Exception” criteria are met in full, then lockout tagout is not required; but the employee performing the work must still be protected using “alternative methods” or safeguarding devices.
2. If the activity does not meet the “Minor Servicing Exception,” then full lockout tagout is required. Once the decision is made that the task does not meet the exception, the team can begin evaluating ways to streamline the lockout tagout process. For example, if the activity is being performed in one isolated area of the machine, can the machine be re-designed to isolate energy sources only in that particular zone so that the remainder of the equipment can continue to operate? This may entail the addition of barriers between zones to prevent inadvertent exposure to those portions of the equipment that remain “live.”
The Catalyst Group’s HSE Consultants have extensive experience in the implementation of the OSHA Control of Hazardous Energy Standard. We’ve helped multiple clients conduct machine and task-based risk assessments and have trained the clients’ internal technical experts to perform the assessments on their own. We have also helped clients make changes to their equipment to address the identified concerns and streamline the lockout tagout process. If you have questions about the “Minor Servicing Exception” or about whether you can streamline your lockout tagout process through improved machine design, please contact The Catalyst Group.