Six Tips to Improve Your Lockout/Tagout Program

This article was written by Eric Prinzing for Occupational Safety & Health.  It is reprinted here with permission.

Lockout/Tagout compliance is a crucial safety requirement. Preventing the accidental start-up of energy during repair and maintenances ensures the safety of workers and helps create a productive workplace.

The OSHA Lockout/Tagout Standard (1910.147) provides clear lockout safety requirements. Despite this, lockout/tagout (LOTO) continues to be found in OSHA’s top 10 most frequent cited standards. It should be seen, then, as a serious and widespread concern. Here are 6 tips to help you stay compliant:

1. Choose the right devices – A lockout device is an extremely important component of a LO/TO program. Machines, circuit breakers, plugs, switches, push buttons, and valves are just some of the items that often require lockout devices. Since there are so many choices, choosing which device or set of devices is overwhelming. There are two considerations that will help: necessity (knowing exactly what you need) and organization (using standardized devices and tools to help keep your devices organized).

   First, determine exactly what you need. OSHA’s guidelines are certainly helpful, but each workplace is unique. Create a list of all machines or electrical components that may need lockout devices. This will make buying the most appropriate devices or kits easier because most are designed to meet a specific application.

   Second, standardize and organize your lockout devices. Lockout Stations are one effective way to store and organize necessary devices. This has several benefits: Not only do stations store necessary devices, but also, they save valuable space and promote efficient operations. If devices are organized in a station, workers know exactly where to find them, when preparing for a maintenance or repair. Padlocks should be standardized by size and color so workers can easily identify function and ownership.

2. Thoroughly Document Procedures – Lockout procedures need to be formally documented. This keeps workers and management on the same page and helps to eliminate any potential confusion. Documentation also provides workers with a valuable training resource. Formal documentation is required by OSHA, but given the differences in workplaces and machines, not every procedure will be the same. It is especially important, then, to make sure the procedures are as effective as possible.

   Procedures should thoroughly detail the steps needed to shut down and isolate hazardous energy. The procedures must describe how to safely place and remove all relevant lockout/tagout devices.

   In order to make the lockout process as easy to follow as possible, procedures should be posted near the relevant machine/equipment. Machine-specific photographs detailing each step are highly recommended. Photographs have a distinct advantage over written instructions or even graphics because the provide a specific and intuitive visual reference point for workers.

3. Clearly Mark All Isolated Points – All energy control points should be clearly and permanently marked with standardized tags or labels.

   Tags and labels should be easily visible. It is also very important to make sure all energy isolation points are consistent with the machine-specific procedures discussed in tip #2.

4. Develop a Rigorous Training Program – Effective training is an indispensable part of a successful lockout program. It can also be one of the most difficult parts because all workplaces and workforces need to be trained according to their specific needs.

    It is important for each worker to know exactly what his role is. Tasks should be clearly defined and clearly assigned to the appropriate worker. There are three types of workers involved in lockout operation: authorized, affected, and other. An authorized employee is directly involved in locking out equipment and machinery scheduled for repair or maintenance. An affected employee is someone whose work is affected by lockout procedures. Usually, this means an employee who works with the equipment being locked out for service or repair. An employee is classified as other if he/she does not work with the machine/equipment, but works in the area where the equipment is located. Each worker needs to know what type of employee he/she is, and strong communication needs to be developed among all workers. Authorized employees must clearly alert all affected employees when a lockout device is placed or removed. In order to prevent unsafe removal of devices, only authorized employees can remove devices they have placed. Lockout padlocks have room for workers to clearly write their names in permanent ink, which underscores the strong need for clear assignments and individual responsibility.

   As with procedures and isolation points, documentation is an important component of training. Recording exactly what types of training have occurred is helpful on several levels. It helps management make sure all workers have been trained, and they are trained for doing the right tasks. Any gap in training can be easily found and corrected. It documents when training took place, which helps workplaces, plan ahead. If you know when your last training session took place, it is easier to plan when the next one should be implemented. Finally, looking at documentation of lockout training can help see your program from a new, more objective perspective. Suggestions can then be taken into account and improvements can be made.

   Training also should be tailored to each specific workplace. If one has a multilingual workforce, for instance, multilingual tools, signs, and documents should be used. Workers should be encouraged to relate their specific safety needs.

   OSHA requires that lockout/tagout training occur annually. Yearly training should be seen as a bare minimum rather than ideal. In many cases, it would be helpful to revisit training exercises more frequently than yearly in order to ensure that critical repairs and maintenance are being done safely. Also, repeat training helps workforces keep a “safety first” mentality. When deciding exactly how much training is necessary, it is important to keep workers engaged in the process and to make sure their ideas and concerns are carefully considered.

5. Evaluate –Careful evaluation is an invaluable tool for improvement. The success of lockout training and written procedures can only be truly gauged after they have been put to use in an actual maintenance or repair situation. Evaluation is necessary to make sure the training exercises, procedures, and devices are working properly. It also affords opportunities to make improvements that may not have been obvious in the training stage.

   OSHA provides rules for periodic inspections. These should be followed closely and provide an excellent foundation for evaluation and improvement. Inspections need to occur at least annually and be performed by an authorized employee who is not involved in the procedure being inspected. All deviations must be corrected and all roles must be thoroughly reviewed. The inspection must also be documented. The date of inspection, procedures, machines/equipment involved, and names of workers performing the inspection must be recorded.

6. Evolve – A good lockout program should always be able to evolve. OSHA may introduce more requirements or stringent guidelines. It is important to make sure your program is up to date. Open communication between all levels of employment also will help your lockout program reach its potential. A program that encourages communication can identify strengths and weaknesses more efficiently than a program that remains static and unchanging after initial training. Employees should be encouraged to communicate which training exercises are working well and which ones need “tweaking”. A lockout program can then go beyond fulfilling minimum requirements: It can be tailored to your workplace and your workforce.

 The ultimate goal is maximum safety for your workers, and all steps should be taken to reach that goal.

https://ohsonline.com/Articles/2016/08/01/Six-Tips-to-Improve-Your-Lockout-Tagout-Program.aspx

Preventing Waterjetting Injuries

You wouldn’t expect latex gloves to protect you from a gunshot. They won’t protect you from water-jetting accidents either.  

An OSHA article describing the dangers of high-pressure jetting notes, “High pressures can cause injuries similar to gunshot wounds, but have the added health hazard of involving contaminated water.”  

In pipeline-related industries, dangers are plentiful. Trenches, excavation, and confined spaces are often touted as the main concerns in risk management, but operators face another underestimated risk on a daily basis — cleaning with water under pressure.  

 “Injection injuries can happen at much lower pressures that are in use in drain and sewer applications. And that carries the risk of infection and tissue damage as well.  …Water injection injuries can appear minor but can cause serious health complications, even at pressures in the range of a consumer pressure washer or drain cleaner,” 

says Peter Wright, association manager with the WaterJet Technology Association and Industrial & Municipal Cleaning Association.  

Despite being generally overlooked in terms of safety across the industry — due in part to a relatively low rate of injury when compared to working in trenches and the like — jetting is a concern simply because of how common it is.  

Lines are jetted for daily cleaning operations, inspections, and rehabilitation: With just about any work involving pipes, water jets are in play.  

 “Trying to get people to understand that you can get injured by a water jet strike is probably the most difficult bit to get across to people,” says Nick Woodhead, president of US Jetting. “We’ve got to start promoting safety.” 

“I think people assume that hoses are not going to burst, and therefore, they are sort of immune. Or they’ve never seen a hose burst, or they’ve never seen a jet injury, so it doesn’t really register. People get complacent.”  

And it’s not just equipment malfunction that operators need to worry about.  

Case in point: Chad Unverzagt, the Indiana operator who was killed in 2012 during a routine sewer blockage. Unverzagt wasn’t killed by an exploding pipe or other malfunction — his hose got loose while the system was pressurized as he was attempting to retrieve it from the pipe. A momentary lapse in a job he’d done a thousand times before and for more than 30 years in the industry.  

With no protective gear, he didn’t stand a chance against the high-pressure water, which lacerated his neck, killing him before help could arrive.  

 “That’s more of an isolated incident, but it’s worth reminding people,” Woodhead says. “That’s why you’ve got to know what you’re working in.”  

A few months after that incident, Cleaner published another Safety First article, highlighting a new line of protective clothing from TST Sweden AB. Though the medium-pressure gear hadn’t reached enough awareness at the time to help Unverzagt, today, operators and their employers have fewer and fewer excuses for ignoring proper safety.  

“The safety gear is essential when you’re running a machine. So many people don’t wear anything,” Woodhead says. “We’ve got to try and get it across to people, it is worth investing in the kit to protect yourself. Even if you’re the operator and maybe the boss doesn’t want to spend the money; it’s worth investing in it, just as a precaution.”  

US Jetting has made it their practice to supply a pair of protective gloves to customers with the purchase of a jetting system, and it has encouraged other manufacturers to do the same.  

Other products like semiautomatic jetting systems give even more options for mitigating risk to operators.  

“OSHA says if there is safety gear available, the employers are bound to supply it,” Woodhead says. “Rather than have government regulation, we’d rather be self-regulated and have people understand (the dangers).”  

Beyond planning for the worst, simple common sense and following standard operating procedure goes a long way to ensuring safety. That includes checking the equipment before each job, performing the necessary maintenance, and assessing each job site before beginning any work.  

“It doesn’t take more than a couple of minutes to do the cursory checks,” Woodhead says. “Once you’ve gotten to your location, you’ve got to do your due diligence. … Just scope out the job for 15 or 20 minutes while your tank is filling up.”  

To get you started, Wright offers a few quick tips to keep in mind:  

“Use a skid that will not allow the nozzle to turn around in the pipe or mark the end of the hose a distance from the nozzle to help indicate the location of the nozzle within the pipe. Ensure the system is depressurized before conducting maintenance or repairs. Ensure the nozzle is well inside the pipe before bringing the system up to pressure,” Wright says.  

It’s easy to oversimplify pipe cleaning, but when the pressure is on, there’s a lot operators can do to prevent accidents — it’s just a matter of knowing how and promoting safety whenever possible.  

“It’s definitely important to have respect for the power and the force of high-pressure water streams,”  

Hearing Conservation

Hearing loss from noise can occur with no symptoms and no warnings of any kind. Its progress is so slow and sneaky that you hardly notice it because you simply adjust as sound reception becomes fainter.

People who work around noise and don’t wear hearing protection probably don’t realize what is happening to their hearing. Most people are unaware that everyday noises such as lawn mowers and machinery have an effect on hearing. Since the damage accumulates over many years, it’s often too late to prevent or reverse what has already been done.

Exposure to a large amount of sound will cause a person’s hearing to worsen temporarily. For most people, resting and avoiding loud noises returns their hearing to its normal level. Hearing loss occurs when a person is continually surrounded by loud noises and takes no precautions so that damage becomes permanent.

Every person will experience some amount of natural hearing loss as they age. Simple steps such as lowering the volume on your TV or stereo can keep hearing loss to a minimum.

Prolonged exposure to loud noises can cause permanent hearing loss, but noise can be reduced before it ever reaches the eardrum by earplugs or ear muffs (most cost-effective), or by using noise dampening materials around machinery. If ear protection is necessary for a job or certain work function, the employer (municipality) is required to have it available and require its use by employees.

5 Excuses for not wearing proper hearing protection:

• “I can’t hear other workers.” – At high noise levels, hearing becomes overloaded. Reducing overall sound levels allows the ear to operate more effectively in much the same way sunglasses provide improved vision in bright light, high-glare conditions.

• “My machine sounds different.” – The sound of a machine will sound different to workers wearing hearing protection, but they will become accustomed to the new sound and will be able to monitor the sound of machines as well at the end of the day as at the start of the shift.

• “I’m used to noise.” – Exposure to noise does not toughen ears. Ears do not become used to noise - workers become deaf.

• “Protectors are uncomfortable.” – Like new shoes or glasses, new hearing protectors need a period of adjustment. If discomfort persists, the device should be exchanged for a different size or type that will fit more comfortably.

• “I’ve already lost some of my hearing; why should I wear hearing protection now?” – Just because you lost some hearing doesn’t mean you’re protected from losing more or all of it. Initially, hearing is damaged at higher frequencies, but as unprotected exposures continue, the damage will spread to the lower frequencies, eventually affecting your understanding of speech. Although hearing protection devices cannot restore a noise-induced hearing loss, they can prevent additional losses from occurring.

It is important to remember, once hearing protection is put on it needs to be monitored. Hearing protection can loosen or be jostled out of position and needs to be readjusted from time to time to be most effective.

It is best to identify tools, machines, and areas where hearing protection must be worn, and have the appropriate types of hearing protection for the type of work.  Train your workers and have appropriate policies and procedures in writing and in place. Supervisors must monitor workers who are in areas where hearing protection is required and hold them to the policies.

Don’t play it by ear. When the job calls for hearing protection, use it!

Distracted Walking: A Major Working Safety Concern

Distracted driving is a well-established problem, so much so that many states have bans in place when it comes to using technology while driving, but the problem of “distracted walking” is a relatively new hazard. Sure, people have been walking out in front of moving objects or stepping off cliffs since the beginning of time, but a new piece of daily-use equipment seems to be increasing the problem – smartphones and tablets. While we might laugh at a woman who falls into a fountain while texting or someone who walks into a glass wall while watching a you-tube video on his phone, the problem with distracted walking is a very serious one.

According to the National Highway Traffic Safety Administration, nearly 5,000 pedestrians were killed and another 76,000 injured in traffic accidents in 2012. While it is not clear how many of these were directly attributed to distracted walking, pedestrian fatalities are getting worse each year, perhaps due to the use of smart phones and other devices.

Common risks associated with distracted walking include: trips, sprains, strains, fractures, cuts, bruises, broken bones, concussions, brain injuries, spinal cord injuries, death, and injuries to someone else. People who text while walking are 60% more likely to be injured or cause injury than non-texters. Scientist call the phenomenon, “inattentive blindness”; they state the human brain can only adequately focus on one task at a time. So, when you are texting or talking on the phone and trying to walk, you cannot give full attention to both tasks. Today we hear people brag about being able to “multi-task”, but our brains cannot efficiently provide adequate attention to more than one task at a time.

It’s not just texting while walking that is the problem. Talking, checking email, using social media, even playing games on your phone/tablet all contribute to the problem of distracted pedestrians. After years of decline, pedestrian deaths have started to increase since 2009, and while there is no reliable data directly related to cell phone use, experts speculate the increase is due in part to distracted users of cell phones while walking.

The solution to distracted walking is a simple one: Don’t use your cell phone or engage in other distracting activities while walking. Focus solely on the task at hand – getting from point A to point B in one piece, and worry about checking your phone when you get there.

Other safety concerns for pedestrians:

• Traffic signals – Obey traffic signals (whether you are driving or a pedestrian). If the traffic signal is not in your favor do not begin crossing, and look before you begin to cross.

• Cross streets at appropriate places -  Jaywalking or crossing the road where there is no crosswalk is a leading cause of pedestrian injury. The NHTSA has found that crossing streets improperly accounts for approximately 30% of pedestrian fatalities.

• Visibility – It can be difficult for drivers to see those walking at night or in low-light or inclement weather. Wear light colored clothing, walk in well lit areas or carry a flashlight, and wear reflective clothing for added visibility.

Take the time to inform employees of the hazards of distracted walking, share with them the statistics, and create policies to reduce the potential for injuries due to distracted walking incidents. It is everybody’s responsibility to help create a safe work environment.

Workplace Distraction Hazards

In a perfect world, employees don’t worry about breaking their arm, falling off scaffolds, or catching a lung disease. In a perfect world, they would be provided with excellent training, not just once, but regularly. In a perfect world, we wouldn’t have to worry about hazards at all. Besides being comfortable and self-cleaning, PPE could be worn in a matter of seconds and would have built-in chemical and radiation detectors. In a perfect world, when a vehicle was about to hit an employee or fire threatened to incinerate them, a bubble, from their PPE, would suddenly encompass them and keep them safe. Being resistant to fire, chemical toxins, harmful gases, and all the negative vibes of the world, the bubble would be the ultimate life and limb saver for the employee on the job. Maybe that’s taking it a bit too far, but you get the idea. All employees, whether they know it or not, wish for a job where they are provided with adequate training and PPE to keep them safe from the hazards in their workplace.

But even in a perfect world, any appropriate training or top-of-the-line PPE would be useless if a worker couldn’t manage one of the most threatening factors on the job: Distractions. Statistics show that distractions are a major contributor to many workplace injuries and fatalities.

Let’s briefly look at the 5 most common distractions on the job:

1. Mental distractions and inattention – Have you ever replayed in your mind unpleasant scenes from home while operating equipment? Or perhaps fantasized about how events will play out concerning your upcoming big weekend plans? Maybe you’ve chatted with a coworker while performing a hazardous task. Mental distractions often lead to inattention, and that could lead to you or a coworker being injured or killed. Whether you are worrying, daydreaming, or just chatting, mental distractions can be just as dangerous as working with electricity or highly flammable materials. Avoid falling into mental distractions. Stay focused on your work.

2. Poor housekeeping – Visual clutter can easily be translated into mental clutter. Frustration from not being able to find something due to a messy workplace can lead to overlooking a safety issue or make you angry enough to resort to aggression or violence. Keep work areas clean and clear of clutter, organize equipment and materials, and keep them in their place. Remember, too, that poor housekeeping says a lot about your attitude towards safety, quality, and productivity. Messy workspace also may give others the impression you are slothful.

3. Machinery – Make sure you perform work at a safe distance from machines, heavy equipment, and electrical hazards. They can impede your maneuverability, hearing, and vision which could cause a mishap or injury due to entrapment in moving parts or a slip, trip, and fall.

4. Hearing – Wear earplugs or muffs when working around loud machinery or equipment. But always ask your supervisor if it is permissible to listen to music or podcasts with earphones while working. It could be a distraction that could be fatal. No music or story is worth your life.

5. Long Unkempt Hair – Many accidents are caused by somebody getting hair caught in machinery or simply attempting to fix their hair while operating equipment. Loose and flowing hair can get in your face and obstruct vision or become a distracting annoyance causing a worker to perform an unsafe task. Tie long hair back, wear a hat, or get a haircut.

In a perfect world, distractions don’t exist, but since we’re stuck in an imperfect universe, all we can do is our job and do it safely to the best of our ability. We can try to help our coworkers to do the same. While some factors in the workplace can play a role in causing distractions, the fact remains that more workplace hazards spring from unsafe acts than from unsafe conditions.