How Do I Know if I Need a Lockout Tagout Program?
If your company has equipment that could potentially cause and injury, and employees that service or maintain the equipment, you most likely need a lockout tagout program. That being said, determining whether you need a lockout-tagout program involves assessing the nature of the machinery and equipment used in your workplace and evaluating the potential risks associated with the unexpected release of hazardous energy during maintenance or servicing activities. Here are some key factors to consider:
- Use of Machinery and Equipment:
- If your workplace utilizes machinery or equipment that has energy sources (such as electrical, mechanical, hydraulic, pneumatic, chemical, or thermal energy) that could pose a hazard during maintenance or servicing, a lockout tagout program is likely necessary.
- Potential for Hazardous Energy Release:
- Assess the equipment to determine if there is a potential for the release of hazardous energy when machines are being serviced or maintained. This can include situations where equipment could start up unexpectedly, causing injury to workers.
- Regulatory Requirements:
- Check applicable occupational safety and health regulations in your jurisdiction. If your business is regulated by OSHA, you should be familiar with OSHA’s lockout tagout standard (29 CFR 1910.147) outlines requirements for controlling hazardous energy during maintenance activities.
- Workplace Incidents:
- If there have been previous incidents or near misses related to the unexpected startup of machinery during maintenance, this indicates a potential need for a lockout tagout program to enhance safety measures.
- Industry Standards:
- Some industries have specific standards or guidelines regarding the control of hazardous energy. Check if your industry or specific equipment manufacturers recommend or require the implementation of lockout tagout procedures.
- Complexity of Equipment:
- If your workplace uses complex machinery or equipment that requires multiple energy isolation points, a comprehensive lockout tagout program may be necessary to ensure proper control of all energy sources.
- Employee Exposure:
- Consider the level of exposure employees have to the equipment during maintenance. If employees are directly involved in servicing or maintaining machinery, the need for a lockout tagout program is likely higher.
- Potential for Serious Injury or Death:
- Assess the potential consequences of an uncontrolled release of hazardous energy. If there is a significant risk of serious injury or death, implementing a lockout tagout program is crucial for safeguarding employees.
If, after considering these factors, you determine that there is a risk of hazardous energy release during maintenance or servicing activities, it is advisable to establish a comprehensive lockout tagout program.
What Do I Need to Get Started With Lockout Tagout?
First, identify the platform you will use to manage your lockout tagout system. While it is possible to write up lockout tagout procedures manually and keep them in a binder or file cabinet, using lockout tagout software is more effective. Lockout tagout software contains a template to complete for efficiently building procedures. Really advanced lockout tagout software even offers a mobile procedure builder. A mobile lockout tagout procedure builder can generate a procedure in mere minutes by allowing the user to snap pictures, annotate the pictures, and add the isolation and verification steps. Lockout tagout software is also used for managing equipment inventory and status, and completing lockout procedures digitally. It offers reporting and analytics to the people overseeing the lockout tagout program.
Next, identify the person(s) who will document the lockout tagout procedures. Procedures should be written by safety professionals who have the expertise to assess workplace hazards and develop effective lockout tagout procedures. If one is not available within your company, consider hiring a consultant to provide training to company employees or to develop the procedures and program for you.
You will also need to purchase appropriate lockout tagout devices including locks, tags, and other hardware. According to OSHA, the devices must be durable, standardized, and identifiable. Each employee involved in the LOTO process should have their own locks.
What are the Ongoing Lockout Tagout Requirements?
Ongoing lockout tagout requirements involve maintaining and continually improving the effectiveness of your lockout tagout program to ensure the safety of workers during maintenance or servicing activities. Some key requirements to be aware of include:
Procedure Audits: Procedure audits are generally conducted on an annual basis. They include a review of the written lockout tagout procedure by an Authorized Employee who is knowledgeable about the equipment and the lockout tagout program. The audits offer an opportunity to document any changes to the lockout tagout procedure and help to ensure compliance and effectiveness.
Employee Training and Training Audits: It is important to provide training to employees that will be performing lockout tagout procedures. Training ensures that the employee understands and can demonstrate the ability to safely execute the lockout tagout procedure. Re-training, or employee training audits, keep employees up to date on any changes to the lockout tagout procedure and offer an opportunity to recertify the employee to perform the procedure.
Staying on top of ongoing requirements is very important. It is also very important to maintain effective communications with employees to ensure they are aware of ongoing maintenance activities and understand the importance of adhering to lockout tagout requirements.
Developing and maintaining an OSHA compliant lockout tagout program may seem like a daunting task, but there are effective tools available to get you started quickly and accurately. The right tools also help to ensure long-term and ongoing compliance. Lockout Tagout software such as Smart Safety Pro Lockout Tagout offer a single platform for efficient procedure creation, management of equipment, audits, and employee training, and digital lockout and return to service execution. A tool like this combined with skilled training when needed will ensure that your lockout tagout program protects your employees and property, manages your risk and liability, and keeps you compliant and free from costly fines.