Lockout Tagout compliance continues to appear on OSHA's Top 10 Cited Standards list year after year. The majority of those citations are due to a lack of proper lockout procedures, program documentation, periodic inspections or other procedural elements. But, it doesn't have to be this way! A little standardization of your lockout tagout programs can go a long way in ensuring the safety of your employees and your overall compliance of the regulation.
What's the benefit of standardizing your lockout tagout program?
You and your facility benefit from standardizing your lockout tagout program by:
Getting started with standardization
Getting started is sometimes the hardest part. Before you can start on your standardization journey, it's important to ensure your current program encompasses the six key elements to a successful Lockout Tagout program. Of course, if you don't have a written process already created, that should be your first step before standardizing.
Where to standardize
Standardized lockout tagout programs are most successful when they reach as far and wide as practical. Oftentimes, a standardized program is only restricted by the scope of your responsibility.
For instance, if you're a Safety Manager within a plant, you may focus on all applicable departments and trades within the plant (e.g., electricians, maintenance, plumbing, etc.) that land under your responsibility. Whereas someone responsible for multiple facilities would include each facility in their standardization efforts.
This even rings true for those who are responsible for multiple facilities in different countries with different languages. In this situation, it's important that the program is translated to accommodate the facilities in those countries. Yes, the regulating bodies are likely different for each country. While it's important to comply with the local regulation, a best practice is to adopt and standardize the more stringent regulation your facilities encounter when writing your policy.
What to standardize
The standardization process can seem daunting when you're just getting started. Here are the places we've found standardization to be the most beneficial:
How to standardize your lockout tagout program
1. Define the regulation your organization will follow.
While each country has its own set of standards, the best practice is to apply the stricter policy throughout your organization to ensure compliance, and add an extra level of safety to your program. It's also important to note that many larger countries such as France, Spain, Germany, Italy, Austria, Switzerland, and the United Kingdom have their own safety directives (BSI, DIN, CEN) that have largely been built on OSHA standards.
2. Create a written program to address the breadth of your lockout tagout scenarios.
Your written program should include:
Assignment of responsibility (who are the authorized employees to perform lockout, responsible persons for implementing the LOTO program, enforcing lockout tagout compliance, monitoring compliance, etc.).
This is also a great opportunity to outline who will monitor and document any necessary and required training, as well as who will provide the training. While your written program doesn't necessarily need to name names, it should at a minimum identify the job functions or titles of who is responsible (e.g., Site EHS Team Lead, EHS Manager, etc.). OSHA requires the written procedures to be periodically inspected at least annually. As part of your standardization, you should set a recurring date for inspection – possibly at a time production may be at a low point for a seasonal business, after regular kaizen events, or following a move of machinery and equipment. That way, your teams can plan for the same timing every year.
In the U.S. in states with their own OSHA plan, it's important to weave any differences between the Federal and State programs into your written plan.
As an addendum to your written program, it's also suggested you complete an asset list or listing of machinery/equipment by location.
3. Use a consistent template for all lockout tagout procedures.
Going beyond compliance, we recommend creating best practice procedures that include machine-specific photos identifying energy isolation points. These should be posted at the point of use to provide employees with clear, visually intuitive instructions. It also:
Investing in a software program, such as LINK360® Software, can further streamline your procedures by making it easier to create consistent and multilingual visual procedures across all of your facilities. It also gives you access to detailed program reports by site area and can be accessed from your desktop, tablet, or mobile phone.
4. Create uniform, consistent schedules.
Uniform and consistent schedules not only help ensure the program is properly maintained, they also help make sure the annual audit is completed on schedule. They can also:
5. Standardize your hardware.
An effective lockout tagout program is most successful when it includes the complete safety picture – locks, tags, and devices, as well as proper lockout procedures, program documentation, employee training, periodic inspections, or other procedural elements.
6. Provide training
Adequate training for employees is important to communicate the processes and ensure your program runs effectively. Training should include not only OSHA requirements, but also your own specific program elements, such as your machine-specific procedures. Site-specific training should be tailored to the following categories:
Standardizing your lockout tagout program not only ensures you're compliant, it also streamlines your entire process by making it easier to maintain, simplifying training, and improving overall usage and worker safety. While standardizing your program may feel daunting, there's help available.
Brady provides a start-to-finish solution, which means we can jump in and help at any stage of your lockout tagout program development. Rely on our in-house team of industry experts to work with you to create a sustainable and compliant safety program supported by: