Make Your Program OSHA Compliant
In 2016 and 2017, lockout/tagout ranked number five on the Occupational Safety and Health Administration’s (OSHA) top 10 list of safety violations. Though it’s too soon to say for sure, the odds are high that it will be on the naughty list again for 2018—but that doesn’t mean you have to be. Recently, we went over ways to make your lockout/tagout program smarter, now let’s focus on getting your program compliant.
7 Essential Parts of a Successful Lockout/Tagout Program
OSHA requires lockout/tagout programs consist of energy control procedures, employee training, and periodic inspections. These three elements must come together to ensure that your employees are safe, preventing injury and even death. While that may sound simple, a typical program can have over 80 separate pieces. From creating, maintaining, and updating equipment lists and hierarchies to task-specific procedures and workplace regulations, there’s a lot that goes into an effective program.
The following list will help you tackle lockout/tagout by focusing on its key elements.
1. Documented Policy
Though you want them instilled in the minds of your workers, policies and procedures must be carefully documented and then disseminated in an accessible format. Your lockout/tagout policies should establish and explain all elements of your program. And OSHA guidelines are just your starting point; you should also consider adding custom requirements as needed to keep your employees safe in their unique work environments.
Remember, safety isn’t something you can set and forget; it requires vigilance and action. So, be sure to incorporate annual reviews into your calendar.
2. Machine/Task-specific Procedures
One size does not fit all when it comes to machine and task safety. You must formally document procedures for each piece of equipment and the relevant work performed. These procedures should include the necessary steps to control hazardous energy, including shutting down, blocking, isolating, and securing equipment. And don’t forget to capture the steps for placing, removing, and transferring lockout/tagout devices.
You should look at OSHA compliance as your minimum requirement. Think about including photos that identify energy isolation points for each machine, and then post them at points of use. Taking extra steps like these will ensure your instructions are clear, easily found, and visually intuitive.
3. Marked Isolation Points
Isolation point verification is critical to any lockout/tagout program. Before you can develop policies and post procedures, you must identify and mark all energy control points, including switches, valves, plugs, and breakers. Mark these points with permanent, standardized labels and tags. And remember to be consistent.
4. Proper Devices
You need to use the best device to fit each lockout point. Though there are many products available, it’s important to select those that are most appropriate and designed for your application(s). The key to ensuring lockout effectiveness is to find the right solution(s) to keep your employees safe.
Policies and procedures aren’t worth the paper (or binary code) they’re written on if they aren’t instilled in your employees’ minds. Now that you have a lockout/tagout program, it’s important to adequately and routinely train your workers to ensure that policies and procedures become action. Training should cover OSHA requirements as well as your custom elements, such as machine- or task-specific procedures. You should also regularly communicate your processes and policies and conduct periodic inspections to enforce your program and uncover retraining opportunities.
Why wait for a formal OSHA audit to uncover faults in your lockout/tagout program? Audits are a great opportunity to improve your program and promote safety. Use OSHA’s audit practices as a guide and look at both performance and compliance in the following groups:
- Authorized employees: workers who perform maintenance on machinery and equipment and use lockout procedures
- Affected employees: workers who use the machines that receive maintenance
- Other employees: workers who are in the vicinity of machines that receive maintenance
A successful lockout/tagout program’s work is never done. Letting your program get stale and outdated will put your employees at risk and leave you vulnerable to OSHA violations. Regular audits and annual reviews will ensure that your program evolves with your work environment and stays both relevant and effective. Maintaining a sustainable program will positively impact your safety culture and reduce costs.
Bonus: 7 Mistakes to Avoid
Now that you have the seven keys to lockout/tagout success, you can further improve your program by avoiding seven common mistakes when creating lockout procedures. Brady® has put together an infographic to cover everything from misuse of generic procedures to lack of verification steps. You’ll learn how to strengthen your program and make your employees safer in the process. Simply click the clipboard on the right to download this bonus content.
Need Help with Your Lockout/Tagout Program?
Whether you need help selecting the right device or just need some solid advice, we’re here to work with you. Our specialists can help you evaluate your needs and make the right selections and improvements to ensure your program is compliant, successful, and sustainable. Contact us today!
What’s the most challenging part of maintaining your lockout/tagout program? Let us know in the comments.
*Adapted from Brady: 6 Elements to an OSHA Compliant Lockout Tagout Program