By Jimi Michalscheck, Business Development Manager — ESC Services, Rockwell Automation, Inc.
Most safety managers will tell you lockout/tagout (LOTO) saves lives. However, a production supervisor, plant manager and many CEOs, might add: “Lockout/tagout is something we have to comply with, but there are times when you just can't lock it out to perform the job. Also, lockout/tagout isn't the only safe way to service equipment so it feels like we're artificially slowing down every time we lock it out.”
Thanks to modern technology and an evolving perspective of how to enforce workplace compliance by OSHA, LOTO no longer is the only tool permitted. Here are some frequently asked questions about LOTO compliance and its alternative.
What is OSHA looking for? Quite simply, OSHA wants you to comply with federal minimum standards (or a respective state OSHA standard where applicable) and follow the rules to protect workers from unexpected restart when they're servicing equipment.
Why is it so complex? It's the upkeep of a program. While most citations are due to lack of machine-specific LOTO procedures, that doesn't mean the program wasn't compliant at one point. Often, companies simply fail to properly maintain the necessary upkeep of the program when they change or add new equipment.
Creating machine-specific procedures for each serviceable piece of equipment in a facility and maintaining those documents annually is a lot of work and often underestimated. In addition to auditing the procedures annually, the authorized employees must be audited as well to ensure full comprehension.
What is LOTO at its core? LOTO uses a lock and a tag on an energy isolation device, such as a valve or an electrical switch, to provide an effective physical deterrent to inadvertent reenergization. LOTO procedures are designed to isolate, dissipate and block all energy from entering the system during the service work. It's effective; however, it's not always the best tool to use for every type of service.
How can a company use something else? Best answer — very, very carefully. If there's an accident related to servicing equipment and a company-approved alternative means of protection didn't work — for example, a guard failed — the onus is on you to prove not only to OSHA (when you're facing a fine), but to a jury when you're in court.
Seems risky, why doesn't a company just lock it out every time? Because some types of service require the machine to be partially live to do the servicing work. Additionally, LOTO might be the best tool when performing major maintenance, but for minor maintenance, the excessive downtime associated with lockout could be engineered out with good alternative solutions like machine guarding, custom procedures and training.
Because of misunderstandings of the federal regulation for the control of hazardous energy, many safety policies are built around the premise that under no circumstances can you service a piece of equipment while live.
Take this story as an example: Steven, a line mechanic with more than 25 years of experience has seen this machine problem before, but this time it was more difficult to identify the cause and fix. A passerby asks what he's doing servicing the filling machine without locking it out. They argue about whether the machine should be locked out or if what Steven is doing is okay. The next day, Steven is terminated effective immediately for failing to lock out the machine while servicing it.
Steven tried to explain to the HR manager that he had to do diagnostic work and there would be no way to complete that work if he performed the full lockout of the equipment. The HR director said, “I'm sorry, this is a zero tolerance policy and you know the rules. These rules exist for your safety and the safety of others.”
Steven retorted “You may not know this, but this company expects me to do what I do in order to keep this business afloat.”
Just a few years later, the company filed for bankruptcy, citing rising manufacturing costs and tight U.S. regulatory restrictions as the reason it must close its doors after more than 100 years in business. Looking deeper into where things took a turn for the worse reveals the overall line efficiency was in decline ever since Steven's firing.
Unfortunately, this story is all too common in the United States. Many companies have safety policies that unnecessarily restrict servicing equipment while partially energized or even fully running. Having a rigid stance on LOTO exclusive usage for all servicing tasks costs companies untold amounts in lost productivity and can actually create a less-safe servicing scenario than if a well-engineered alternative is used.
OSHA wrote in an exception to the LOTO clause: 1910.147(a)(2)(ii)(B). An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.
Note: Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they're routine, repetitive and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).
However, before you stop using lockout, you should know that since releasing this regulation in 1989, OSHA has cited hundreds of companies for using this exception. It's not that you can't use the exception, it's that you can't use it to increase the risk of exposure to the employee.
So if you're going to have an alternative procedure, you had better be sure it's effectively equivalent to LOTO or you'll be cited for failing to comply.
Here's another way of saying it: OSHA requires that you have a LOTO procedure to provide protection during any type of service from lubrication and unjamming all the way up to installation and removal of the equipment.
While OSHA doesn't require additional procedures to help make productivity improvements, its not saying you can't either. OSHA's stance is that as long as it's proven to be as effective as LOTO for the particular service then it's permitted.
So what does it mean to be “as effective as LOTO?” Good question, and nobody really knows, because there's no way to prove you're right, only a way to prove you're wrong — when there's an accident.
Industry best practices are evolving quickly and companies are realizing that LOTO is not a production killer unless you let it be. By taking another look at the overall LOTO safety program, companies can oftentimes reengineer their safety program to incorporate Alternative Protection Measure (APM) procedures. These procedures serve to control the machine in a safe state so authorized workers can safely perform a prescribed service.
To successfully implement an APM program, a company must plan accordingly to list the machines they want to engineer in alternatives. Then, whatever procedure they develop must have limitations to what servicing activities can occur and what areas of the machine this covers. Lastly and most importantly, a properly engineered safety program must include means to verify that the procedure was effective — every time.
So why take the risk to develop APM procedures? Because your people are likely already doing it, and it's not being documented. If someone gets hurt, your company will be in hot water by allowing it to occur.
Remember one golden rule when creating a modern LOTO program and engineering out LOTO: No additional risk can be introduced to the employees by using alternative procedures. 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.
DISCLAIMER: While it might be possible to engineer out many servicing activities with well-engineered safety procedures and high performance hardware, Rockwell Automation always recommends users follow LOTO regulations when performing service on equipment where no “company approved” safe alternatives exist. Lastly, users shall assure themselves that all maintenance and servicing procedures are safe, effective and properly tested according to good practice and regulation.
ESC Services, a Rockwell Automation Business, focuses on delivering advanced safety services and solutions that yield a balanced approach to help enhance both safety and productivity.