Lockout/Tagout is one of OSHA’s top ten most-cited violations. In some instances, workers are hurt or killed because there are significant gaps in training, safety equipment, or procedures. Even companies with carefully developed lockout programs and procedures can make critical mistakes. Lockout training should emphasize developing good habits and careful reevaluation. This short list emphasizes five commonly made lockout mistakes.
1. Loose Clothing
Loose or tattered clothing also presented a hazard to workers operating or working near machines. According to a Bureau of Labor Statistics study, over one fifth of machine-related fatalities occurred after an article of clothing, such as a glove, pant leg, shirt, or coat sleeve, was caught in the machine. All deaths involving power take-off equipment or driveshafts all occurred after the worker’s clothing was caught in the equipment.
Clothing policy must prohibit loosely-fitting clothes or accessories for workers operating near machines. To prevent loose clothing from being caught in pinch-points you may wish to adopt a uniform policy or require a clothes review as part of your pre-work safety inspection.
Even companies with carefully developed lockout programs and procedures can make critical mistakes. Lockout training should emphasize developing good habits and careful reevaluation.
2. Reaching Through or Stepping Over Equipment
Some employees may think that since they are not directly repairing or maintaining machinery, they do not need to observe lockout procedures. Any time a worker needs to remove a guard or puts any part of their body in a danger zone, lockout procedures must be followed. When possible, workers should be restricted from opportunities to place their body near moving parts. Comprehensive training and retraining is important in this regard because workers may not think they are performing lockout tasks. Installing signage that identifies dangerous machinery and pinch points can help increase worker awareness.
3. Poor Jam Prevention
One good way to prevent accidents during repair and maintenance is to proactively prevent jams from occurring in the first place. Ten percent of the fatalities in the above-referenced study occurred while the worker was unjamming a machine. If possible, develop methods to clean and lubricate moving parts without requiring workers to get near moving parts or pinch points. Installing extended oiler tubes are a good solution for machines that have moving parts that are difficult to reach.
Remember, if a worker must place any part of their body near a danger zone or pinch point, lockout procedures must be followed before any attempt to unjam the machine takes place.
4. Failure to Drain Residual Energy
Even after locks are applied, a machine may still be dangerous because residual energy may still be present in the system. Its is extremely important to drain all energy after lockout devices gave been applied. The method of draining energy will depend upon the type of energy and the machine itself.
- Electrical Energy: Many systems with electrical components use capacitors, which store electrical energy. Electrical energy can be especially dangerous because it can be released very rapidly. To drain residual energy, capacitors must be thoroughly discharged. If you are not sure how to discharge energy from a capacitor, contact the manufacturer for specific instructions.
- Hydraulic/Pneumatic Energy: Even after valves are locked in the closed position, lines often contain residual energy as pressurized fluid or gas. To drain the residual energy, use pressure relief valves to bleed the lines. If pressure relief valves are not available, contact the manufacturer for instructions regarding removing residual energy.
- Mechanical Energy: Coiled springs can cause potentially unsafe release of energy. If springs are still compressed, carefully release them according to the written lockout procedure. Blocks can also hold potentially moving parts in place.
- Gravitational Energy: To prevent falls, lower all movable elevated parts.
If you are unsure how to dissipate residual energy, contact your supervisor. After you have drained residual energy, always make sure to test the system to verify that no energy is present.
It is important to think of Lockout/Tagout compliance as an ongoing process. Compliance requires continual attention.
5. Failure to retrain or update procedures.
If your workplace has taken the time and effort to develop a thorough energy-control program with written procedures and trained employees, you might think that your lockout program is complete. However, a compliant lockout program is an ongoing process. Yearly audits must be conducted to make sure lockout procedures are being followed. Retraining must also occur whenever new machines are introduced or whenever trained workers are given a new assignment. Aside from these requirements, a workplace culture should be developed in which workers are encouraged to voice any concerns or suggestions concerning lockout/tagout. Workers are directly familiar with their jobs tasks and thus have an important and unique perspective. For instance, a worker might suggest a more efficient or thorough lockout device for a given machine. Carefully considering the input of employees can lead to a safer and more productive lockout program.
Lockout Registers can help you organize your Lockout/Tagout program.
It is important to think of Lockout/Tagout compliance as an ongoing process. Compliance requires continual attention. A good training program and careful implementation can go a long way toward improving and maintaining your lockout program. If you have any questions about Lockout/Tagout procedures or products, don't hesitate to reach out to us here.