Properly Controlling Hazardous Energy with Correct LOTO Training
Why do I need to be concerned about Lockout Tagout (LOTO)? Employees can be seriously or fatally injured if machinery they service or maintain unexpectedly energizes, starts up, or releases stored energy. OSHA's standard on the Control of Hazardous Energy (Lockout/Tagout), found in Title 29 of the Code of Federal Regulations (CFR) Part 1910.147, spells out the steps employers must take to prevent accidents associated with hazardous energy. Practicing LOTO not only provides workers with protection from industrial machinery, but also protects your company from extensive OSHA fines that be detrimental to company reputation and finances.
What topics are we going to cover:
- Why do companies need to comply?
- Understanding the OSHA standards on Lockout/ Tagout
- Understand the steps to make sure your program complies
- What are energy sources?
- Types of Lockout Devices
Jamie: Hello and a warm welcome to everybody. We'd like to wish everyone a good morning, a good afternoon, or a good evening, depending on where you are in the world today. My name is Jamie, and I'm one of the co-founders of Safeopedia. Safeopedia’s mission is to support the EHS professional, operational folks, and any safety-minded individuals with free safety information, tools and education.
I'd like to extend a huge thank you. We're super grateful to those dedicated professionals for the great work they do on a daily basis. Just a reminder, the webinar is being recorded, and we’ll be sending out a link to everybody in just a few days. The webinar is for you, the audience, so let's keep it interactive. Get your questions into the GoToWebinar control panel as we go, and then we'll get to them at the end of the presentation.
Today, we're proud to present “When in Doubt, Lock It Out: Properly Controlling Hazardous Energy with Correct LOTO Training”. This Safeopedia webinar is being presented by National Marker Company, a Preferred Manufacturer member of Safety Network. Safety Network demands excellence, so demand Safety Network.
It is now my absolute pleasure to introduce you to today's presenter, Bryan McWhorter. Bryan is a productivity expert and safety professional with over 10 years’ experience in implementing and teaching safety, leadership and productivity tools. He gained much of his knowledge and experience through over 30 years as a supervisor, safety officer, and senior trainer in the manufacturing industry at the largest fluorescent lighting factory in the world. He's also been training workers how to remain safe using lockout/tagout since 2009. All that crazy work-related stuff aside, I've known Bryan for a few years, and I not only consider him a good friend, but he's one of the most generous, kind, knowledgeable and hilarious people I know. I'm very grateful to have you sit back, relax and enjoy this presentation. With that my friend, Bryan, please take it away.
Bryan: Thanks, Jamie. I'm blushing. What a great introduction. Thank you! I like to thank everyone for joining us today. This is a very important topic, and I'm going to try my best to give you some really good information. You should walk away with a lot for the time that you spent watching this. So, with that — uh, there we go — delay on the computer — “When in Doubt Lock It Out”. We're going to cover all the aspects of lockout/tagout, so properly controlling hazardous energy correctly using lockout/tagout.
Okay, the OSHA regulation is 1910.147, and it covers the servicing and maintenance of equipment where the unexpected release of energy at the start could cause a start up of equipment or produce some type of hazard that creates a risk to the individuals working on the equipment. It establishes the minimum performance requirements for controlling hazardous energy, and it states that all new equipment installed after January 2, 1990 must be designed to accept lockout/tagout devices.
There are some exceptions in the fields of construction, agriculture, and maritime, such as the installation under the exclusive control of electric utilities for the purpose of proper generation, transmission, and distribution, including related equipment for communication metering — also in oil, gas well drilling services. However, there are exemptions for those exemptions, and that's anytime that you're removing guards, and the equipment has to be ran and people may need to interact with that equipment while it's running. If that's the case, you still have to use lockout/tagout.
Okay, the history of lockout/tagout: Lockout/tagout was created in 1982. It went into effect in 1989. There are lots of citations every year for not following lockout/tagout or having energy control program. This lockout/tagout was created by OSHA, so it's their baby, and I have no problem enforcing it. If you saw that first slide that stated that they estimate that 50,000 injuries and 120 deaths are prevented each year because of lockout/tagout, you see why they are so adamant about enforcing it. You're not going to have a lot of success in arguing against getting out of citations when it comes to energy control programs. That third bullet, look at that. 95% of all lockout/tagout citations involve the failure of having a formal energy control program in place. That's pretty significant — not having any energy control program.
So, I visited companies where they had none in place. They had no effort yet to get lockout/tagout going, And I have visited companies that had very strong lockout/tagout programs that they were very proud of, and it gave them confidence. You know, if you're one of the first ones that don't have it in play yet, hopefully this presentation is going to give you a lot of good information to give you the confidence to get that ball rolling. What I would challenge you at is by the end of the day, make those first steps in that commitment to get that program in place. We're going to give you a lot of good information to help you. When it comes to citations for lockout/tagout, in 2017, it was number five in the top 10 that type of citations that OSHA gets. So, every year it is one of the highest forms of citations.
Okay, so let's look at some definitions. An energy isolating device — this is the actual device that protects people from being able to turn on that source of energy. So, manually operated electronic circuit breaker, disconnect switch, line valve, a block, any similar device used to block or isolate energy. Note: Push button, selector switches, mechanisms on the machine that you use to turn it off are not energy protecting devices. It has to be something you add to it.
Okay, I'll talk a lot in this webinar about leading indicators and triggers that should indicate that you need to do something, and everything that you see to the right of the screen there are an activity that should trigger bringing on lockout/tagout. So, anytime you're doing any type of constructing of equipment, installing equipment, you know setting up, adjusting, inspecting, modifying, lubricating, cleaning and routine maintenance, you've got the equipment down, these should trigger that you're using lockout/tagout.
Okay, sources of energy. Lots of different types of energy out there. So, you got mechanical, hydraulic, electrical, gas, pneumatic, water, chemical, thermal, gravity, other stored energies, think physics. Anything that can put things into motion is an energy source that you will have control over.
Okay, let's look at compliance first. Okay, this is the six-step process that your lockout/tagout will always follow, and I'm a big fan of systems that use check sheets where you can just follow a very simple structure. So, here it is for lockout/tagout.
Step one: notify and clear all affected employees. Anyone that's in the area, let them know that you're going to shut down the equipment. Shut down the equipment you use under normal process. Isolate all related energy sources. Apply your lockout/tagout device you use — device for every energy source if needed. Control the stored energy. Release, you know, turn valves release, capacitor banks, bleed off any energy that's there, and then verify that the energy is isolated by trying to start the equipment. If you see the picture there, we've got that valve that's being covered by that plastic casing, you know, with the danger sign on it. That is the lockout/tagout, the energy control device. So, they put that over the valve, apply their locks and tags to it, and you have lockout/tagout of that valve.
Okay, the compliance steps. So, for your entire lockout/tagout program from inception to deployment, here are the three steps you're going to follow. First is do establish a written program. So just like any other safety program, you know, for hearing conservation, you'd have your hearing conservation program. Respirator program, here, you've got your energy control program. So, you put first then in writing. We'll talk more about that here in a minute.
Then training, you can have the greatest programs of the world, but if people aren't training and training as inadequate, then there's a problem. So, setting up the training, the initial training, and how you're going to verify that that training is effective. Then you're honest for the program itself. Again, employees know that we monitor and manage what's important to us, so that program has to have regular audits and times where you're going to go out and verify that it's actually being done. But, you know, roll out the program. So, you've got everything in place, now you've got the locks, the devices, the instructions all deployed out across the floor.
Okay, so what is the Energy Control Program? This is going back and answering that first question there of establishing your program. So, what needs to be in that program? Basically, it's the what, why and the how, so you've got the scope, the purpose, who's authorized, the different classifications, all the rules and the techniques that you're going to use for lockout/tagout. You’ve got to include a statement of the intended use of the procedure, then we're getting into the how. All the steps that are going to be taken to ensure the lockout of you know, hazardous energy is being performed. That includes identifying the hazard sources, making sure that people understand how to verify that it has been locked out, and again, that you've got audits in place to make sure that it's actually being done.
Okay, so where do you begin?, What you don't want is, look at this, if you’re one of those companies that doesn't have anything in place yet, I don't want you to look at this from the standpoint of wow, you know, put together that procedure and go down this road. It’ll take months. Think with a little bit of Nike attitude of just doing it.
Okay, you're going to begin with a hazard assessment just like you would for any other safety topic. So, list all the pieces of equipment that you have, that you have in service. They might be just being stored right now, but ready to go into service, or equipment that’s broken down. But you want to do a hazard assessment. First, list all that equipment, so you've got all that captured, then look at the hazard assessment for each piece of equipment, identifying all the different types of energy that is capable of being released in that equipment.
Okay, once you've got that done, okay, the next step, remember, after you've got the program and you've started doing the hazard assessment, you capture the equipment, now training. Again, and this is something that I do often see a weak area, which really kind of intrigues me at time. Where you’ve got a good program in place, don't let it fall short by not having good training programs in place. So, this means the initial training for the individuals where they're trained on all those aspects in terms of the what, the why, and the how. So, they need understand why it's important, why you're doing the energy control program in all aspects as it involves them. So, it has to be good initial training. You need to document all of it and have the training set up on a schedule for annual training and retraining when you see certain triggers, that we’ll talk about also in this presentation.
Retraining — okay, there are certain triggers or flags that should let you know that you've got to review your training again, and these first three are because of changes. So, anytime you have a change of job assignments. So, Erica is one area and now she's going to be working in a different area, where now she has to be authorized and trained to do lockout/tagout for this equipment. So, when there are personnel changes, changes to the equipment itself. So, you change something about the equipment or you've changed the lockout/tagout procedure. So, for any of those, those are triggers, you know, a leading indicator to let you know that you might have to do some retraining with, like, a tagout.
That last one is, you know, anytime that you see that there's a deficiency in some way through one of your audits or reviews, you see the lockout/tagout wasn't properly followed, then just like any other inadequacy, you want to follow it up with some retraining, and then verify that you've corrected the situation. That person now is back on track with doing proper lockout/tagout.
Annual inspections — like I mentioned that, you know, for any program, employees know that we give attention to things that are important to us. So, here are some flags, some triggers, some leading indicators that let you know the lockout/tagout should be in use. So, this is a great opportunity to go out and watch it and verify that it's being done. So, construction of new equipment, installation of new equipment, modification or adjusting of equipment, all your routine cleaning and maintenance, major repairs, changing an employee, so again, change of personnel. So, with any of these, these are your opportunities for lead supervisors, your safety manager, to go out and verify that lockout/tagout is in place, and it's effective.
Again, the honor system that is at work, we want to go out and verify and actually document these. Okay, if you're not sure, just like that first slide stated, when in doubt, lock it out. Remember those exemptions to the exemptions we were talking about earlier where if you've got guards that are removed or bypassed and people have to interact with the equipment, it absolutely has to be locked out. If you got that hazard assessment, if you got energy that someone could come in contact where they can put, you know, the equipment back and use or put something in motion, you got to have it locked out.
Okay, let's look from a personnel perspective. There are three groups of people we're going to look at. We've got authorized, affected, and other. Okay, authorized are the individuals that are actually going to be performing the lockout/tagout. So, they've got to have the highest level of knowledge, skill and training. So, they've got to understand the purpose — again, that what, why, and the how. They've got to be able to recognize a hazardous energy that they could come in contact with. They have to understand the type of magnitude, the severity of it — again, you know, give them the respect for it — and to understand the means for shutting it down, locking it out, and for verifying that it has been properly shut down. So, again, be able to try to start and verify that everything is okay, everything worked out fine, and now the equipment is safe to be worked on.
Okay, affected employees, that’s our second group. So, these are people that are not going to perform the lockout/tagout, but they're going to possibly be working in the area. A good example would be, say, in a production factory where you have machine operators, and you have the maintenance crew that come and actually do the work on the equipment. So, the operator steps away, the maintenance guy applies his lockout/tagout. For the person that's working around there, the operator, he just needs to be aware. So, this is all awareness training for him, making sure that he understands what that lockout/tagout means and to stay away from the equipment until it is done and ready to be brought back up, and you know, he is being able to take over ownership again. So for affected employees, remember it's all about creating awareness.
There's a third group, and this is kind of a catch-all. These are for people that might be working in the area, say office workers that might be roaming near where the lockout/tagout is being done. Here's kind of a good rule of thumb. In any facility that I've been at, usually we’ll do lockout/tagout training from an awareness level for everybody, so for all employees. So yeah, if you're in accounting, you're still going to get the lockout/tagout training. Then it'll be a little bit deeper for the affected, just mainly from the standpoint of going out and making sure they understand that when their equipment is after lockout/tagout, they leave it alone, and then the deeper training for those who are authorized. But you want to cover it from a standpoint of awareness with everybody who is, could be around the equipment.
Employee reviews — again, I mentioned this earlier, you don't want to go on the honor system, as in do the training and, you know, once done and then walk away. We always want to verify. So, just like doing forklift training, when you train someone for a forklift, you're going to do an observation and training with hands-on. Well, same thing with lockout/tagout. When someone has been trained, then you want to observe them actually doing the lockout/tagout. And capture the observation just like training. Put it in their file, put it in the database that you observed Joe doing lockout/tagout and saying what the affected employees, that you've discussed it with them and have done some observations. Make sure that, again, everything is in place, and you've got real good confidence in the system. And do this from time to time, but definitely an observation for the first few times after the training has taken place. You got to verify that it's effective.
Okay, group lockout/tagout — now we're getting a little bit more complicated, but still the structure for this is very simple. It's not like synchronized swimming, although you're trying to get everyone to work together. So, you've got, say, a group of individuals, say, a maintenance team of five people who are now have to work on a production line that’s down or a large piece of equipment. The easiest way to keep track of everyone is to use that group lockout/tagout. So, you have a device that can handle, say, five locks. You know, for the five individuals, they each put their lock and tag on there, and the equipment doesn't come up until each of those locks and tags is removed. And there have been accidents that have occurred when, say, someone decided not to put their lock on. The others removed theirs and assumed that person was done, and they start the equipment. That's why it's very important that this is your safety device, your tracking mechanism. It's also a good idea to maybe have one person that's in charge of it when you have several people doing a group lockout/tagout. She might have a lock box where everyone puts their locks in, or their keys in after locking out, and then one person oversees that lockbox. But at least have one person that is kind of in charge of the situation and verifying that it's being deployed the way it should be, and they're kind of in charge to do it.
Okay, another situation that you want to definitely be watching for is, we're looking for continuity of our program, for lockout/tagout, no matter what's going on. And part of this is a change of individual certain shifts. We want to watch this. So, I'll give you a scenario. Let's say you've got — I am working on the first shift, and I’ve got a machine that lockedout/taggedout, and I didn't get all my work done. So, I've got to pass it off to Jamie who’s a mechanic on the second shift.
Now, I know Jamie's upset because Bryan didn't get his work done, and now he's got to finish it. But I know he's really just upset because he’s stuck on second shift, but that's a discussion for another time. The main thing is when you're passing it from one shift to the other, here's the scenario, here's what you want. During that handoff, you are both people meeting in front of that lock. So, I would remove my lock and tag in the presence of Jamie, then he would put his lock and tag on it. You want that continuity. You never want a time where someone's going to remove that lock or tag, and that equipment sets unprotected, you know, without lockout/tagout on at waiting for someone else is a handoff. So, have those procedures in place for shift change, personnel change, where you've got it documented on how you're going to handle that handoff.
Okay, unusual conditions, especially in manufacturing, this will always come up. You're going to have a debugging process. So, at some point, you're going to have to remove the lockout/tagout and energize the equipment to run it and verify that you don't need to do some adjusting, or you know, changing things. Okay, when you're doing this, you still have to verify that there is safety to whatever extent that you can keep people safe. So, it might mean putting out tape and making sure the area is clear and having someone standing by at a distance to keep people from an area from getting close to the equipment while you're doing your debugging. But remember those exemptions again. If you have guards off, and people have to interact with the equipment, you still have to have lockout/tagout. So, that means during debugging, you put those guards back on, and you keep people away.
Okay, contractors. Again, we're still looking at maintaining continuity of the lockout/tagout program no matter what's going on. So, if you have contractors coming in and they're doing work, they still have to follow lockout/tagout. So, my suggestion is have this as part of your contractor packet. When you're working with contractors setting everything up, make sure you cover lockout/tagout if it's applicable. They've got to be able to match what you have going on for lockout/tagout. So, 99% of the time when I talk to a contract if they're doing work, they're equally up to and trained in utilizing lockout/tagout. So, again, if they're a group that she used to work in equipment setting it up or putting in equipment that utilizes energy, more often than not, they're going to have a good lockout/tagout program. If not, then you got to cover that gap somehow. You've got to make sure that your people are doing it or they're following your procedures, but lockout/tagout has to still be in place. You need that continuity.
Okay, typical shut down procedure — and again, I love checklists, I love simplicity, so here's what you're going to follow when you're applying the lockout/tagout. Notify the affected employees. It makes sense, so everyone in the area that could be affected, you know, let them know that you're going to shut the equipment down. Use a specific procedures outline. Now I love that it’s bullet point because that says you have to have procedures in place.
Again, don't go on the honor system. Have a check sheet, have something setup where here's the procedure for shutting down this equipment. Shut off the energy sources to the affected equipment. Use a normal stop/running procedures. Again, use the stop button, turn the valves, the switch is your normal procedure for shutting it down. Now affix your lockout/tagout devices, your energy controlling devices, like that red casing that you saw going over that valve. You to put your case in place, put your lockout/tagout on them. Relieve all stored energy at this point from capacitor banks, springs, compressed air, hydraulics, you know, anything and pipes, but release that energy. Then that last step is always going to be, you’re going to verify that they energy has been dissipated, and it's locked out. So, you're going to hit that stop/start, and verify that the equipment is safe.
Okay, now you've done your work, and we're going to bring the equipment back up. So, the first step is to ensure that the non-essential item has been removed from the equipment. And I don't know how many times I've seen equipment being brought up, and they miss some tools or something on there that falls into the equipment, and now it's back down because it's been damaged. This is also a good time to mention 5S and TPM. Again, if you have shadow boards or tools that are hung up, it's easy to see if something's missing and to look on that equipment. But at the very least, your lockout/tagout check sheet should have that on there as that first point. Ensure that non-essential items, everything's been removed from that equipment before you're ready to bring it up. All guards and everything had been put back on, everything's intact. Check the area to ensure all personnel are moved away from it and everyone's informed that you're bringing the equipment back up, putting it back online. Notify all affected employees, supervisors — again, any stakeholder around that area that could be involved either way without equipment. Remove the lockout/tagout device that re-energize the equipment.
Okay, let's look at some limitations when it comes to lockout/tagout. When doing lockout/tagout, it's important to understand that, you know, we're trying to keep people safe. So, we're protecting the people that are going to interact with that piece of equipment. Here’s the importance of locking it out: we want to make sure that the tag is being used, and locks are up to the task of handling the environment that they're going to be in. So, that tag, you know, if you're buying a lockout/tagout tags or you’re making them, they've got to be the type that are going to handle the environment that they're in. The attached device has to be able to handle at least 50 pounds of pull. They've got to be able to withstand the environment. Bottom line is, you don't want those tags to, you know, be torn off, ripped out or come apart until they're actually removed. So, they cannot — you know, that's not something that is possible to happen. You want the blockout/tagout done in a way that, again, it’s not going to be removed until the person that applied it is ready to remove it.
Standardization is also extremely important, and it’s part of the regulation for lockout/tagout. The device that you're using for lockout/tagout are only to be used for lockout/tagout. The idea of standardization is it makes them stand out too. So, you want people to be able to easily see those tags that denote lockout/tagout. They've got to be visible, so at a place that people can see them, but you know, you want only the certain type tag used, same font, same structure, same color. Same with the locks, same with the devices. So, you've got to have a system within a system where you've got control of everything used for lockout/tagout, and everyone's trained to recognize it. This way, lockout/tagout becomes much more visual. It kind of just keep communicating for you. It kind of waves its hand and lets you know that, hey, this device is locked out and this is part of the lockout/tagout for controlling energy.
Okay, the lockout — whenever you’re doing lockout/tagout, okay, 99% of the time you're going to be locking it out. You can only use tagout if you can verify that it's going to provide the same amount of safety as if you were using a lock, which is going to be very difficult to do. So again, the majority of the time you're going to do a lockout, and then the tag is what's going to draw attention to it, lets you know who tagged it out, so it kind of gives some ownership to it, but you'll be using those in conjunction with one another.
Tag out limitations — yeah, again, if for some reason you are using a tag, remember it's just a warning. So, you're kind of back onto the honor system. So, this one kind of really denotes the importance of good training so that again, people understand or respect the importance of that tag. Again, that is there to provide protection, and no one removes that tag except for the person that put the tag on. Again, that tag is never bypassed or removed. In all my years of dealing with safety, I can think of only one time where I have seen that happen, but it's worth mentioning because it talks about human behavior.
I had a mechanic once who worked in the same area for about 15 years, and he is used to maintenance, always bringing equipment back up or being done well, say, by like three in the afternoon. Well, he worked in the same area, you know, every Thursday at three, maintenance is done and he brings up the equipment. Well, this particular day and for whatever reason, maintenance didn't lockout/tagout the equipment, they just put a tag on it. Well, it was three o'clock, which to him meant it was time to bring up the equipment. Well, the power of habit overrode his training a lockout/tagout. He removed the tag and brought up the equipment. Luckily, no one was hurt, and he did have repercussions and retraining that and to go there. But it shows the power of habit, the power of human behavior. If you can lock it out, lock it out.
Again, that's what is truly required. The lack of tagout is just, again, that's a warning. But remember that tag does need to be on there for lockout/tagout. It's got to be able to handle the environment, which reminds, again, it's got to be able to handle about 50 pounds of pull. So, you don't want something that's flimsy that could easily be removed accidentally. It's got to be up to the task of handling that environment.
Okay, so in summary, accidents are going to happen. We're planning for this, we're anticipating. Equipment is going to malfunction, it's going to need maintaining, it’s going to need maintenance, it's going to have to be worked on at times. People will make mistakes, so this is why we have safety programs. Again, safety is either proactive, or it's inactive. In almost every area of safety, we need systems and programs driving our efforts. So, there's no excuse for serious injury the results from ignorance, carelessness or complacency, or the lack of an energy control program. Again, we need that lockout/tagout program in place. So, with that, we'll be able to take some questions, and thanks for listening.
Jamie: Thank you, Bryan. Yeah, quick reminder, get your questions in. It's quite a few questions in already, so why don't we get right to it. Bryan, are you ready?
Bryan: I am ready.
Jamie: All right. All right, the lucky winner of the first question is Jason. Do we need to have a written procedure for every single piece of equipment we lockout and tagout?
Bryan: No, not necessarily. The main thing that differentiates or kind of designates it is the difference with equipment. So, let's say you have several machines that are identical. No, you just need to have the procedure in place for how to do it. But if you have different pieces of equipment with different types of hazards, then yeah, you do need it because again, that's — you don't want to just think that that person knows. You want a check sheet in place. So, you want to verify that you have kind of a how-to for all the types of hazard that go with that piece of equipment. So, to answer your question, again, if you have several pieces of same type of equipment, no, you don't need something for every one, but for all the different types of hazards, you definitely do need written procedures.
Jamie: Great, thank you, Bryan. Alright, Peter has a question. I think it's a free question. He says are you able to answer questions about LOTO when it comes to hydraulic line? Can you answer this to the automotive field or construction equipment? So, I think he's asking if you have some experience in the automotive field or construction equipment. So, Peter I would say, if you can get your question in, or, Bryan, if you could talk a little bit about hydraulic lines if you have experience in that that area.
Bryan: A little bit. Again, in a lot of these programs interlap each other. This is why you'll often see lockout/tagout also connected with confined space and respirator training. So, again, when you're talking about materials traveling through a pipe, you're dealing with energies, true, but you’re also going to be dealing with substances that create a different type of hazard, like poisonous gases or things along that line. So, lockout/tagout still needs to be applied.
The real point is that you've done your hazard assessment, so you've looked at from an EPA and a safety standpoint, what are the potentials for those materials to, (1) be released into the atmosphere, or be released in a way that causes harm to somebody when you didn't want it, you know, going through that pipe. So, it still comes down to the hazard assessment, understanding your system, and again, it could go for natural gas or for anything. And the complexity it might cause for a little bit deeper training or a higher level of expertise like bringing in some engineering to help make sure — like, with gas. When you're talking about natural gas, looking at backflows and potential for explosions, you know, there's a level of expertise there that definitely goes beyond me, but it'll be captured again with that hazard assessment and whatever would be the industry standards for safety for that field. That's what's going to be expected anyway. Hopefully that helped. I kind of rambled there.
Jamie: Awesome, thanks. And, Peter, if you're out there, if that didn't answer your question, please elaborate. We'd be happy to follow up.
Robert has a question here. Oh, I'm sorry — Steve. Sorry, Robert. Do we have to have a lockout/tagout log?
Bryan: You know, I've always encouraged it. I've helped implement lockout/tagout in several facilities, and I’ve had them implement logs, and here's why. We live in a world where two things I'll give you: one is it goes with that safety is proactive, so a log is a great way to make it proactive. We live in a world where if you can't verify or give evidence, it's hard to prove that something is taking place. So, a simple log book, again, kind of one of the best practices that I've implemented in different places. You know, where they do the lockout/tagout procedures, very easy to have a log book where, you know, the person that performs a lockout/tagout, and it's a good idea to have a check sheet for this anyway. So, then have some, you know, paperwork you're filling out.
Again, we're creatures of habit, and we're always thinking in the future. So, having that check sheet and that log book kind of snaps us into the present, you know, it gets us doing that that proactive thing again. And for me, when I was a safety manager, say, at that lighting facility, I would go around to the different places that I know use lockout/tagout, and I would periodically check the log book. You know, like, once a month I’d go around and look, and you know, if I knew that maintenance had taken place and someone hadn’t signed that log book that told me there's a deficiency that you know I needed to go and do a little investigating. So, that's why I encourage it.
Jamie: Thank you, Bryan. Okay, I'm going to try and summarize. Claire has asked a few similar related questions. Claire, forgive me if I mess this up. So, she's talking about spare keys. How many spare key should there be for locks? Who oversees them? Were hidden and is that right procedure for it? And it’s good to have a procedure for spare keys, and if a key breaks the procedure, especially if less keys, do we need to get a fresh key? And talk a little bit about that, and then she talks about would you recommend the keys with patterns on them to stand out? So, if you can talk a little bit about control of the keys, spare keys, everything to do with keys.
Bryan: You betcha. Again, interesting question, a good question. Actually this kind of covers into and segues into a different area. This is more of a security standpoint. For lockout/tagout, you want one key for that lock, and again, in some cases you need maybe the lockbox and deal with groups or whatever. But typically, it's one key for one lock, and that's it. You want control over that key with a young person who's controlling the lock. That being said, you might be in a situation where, you know, the maintenance person needs to have a spare key. That's fine. The main thing is that you have your controls in place, so you can show that you have ownership of the system.
Now from a security standpoint, having keys, extra keys — as long as you can show control, I don't have a problem. I think it's probably not a bad idea. So, having your lock boxes or your spare keys to where you've got a control point for them, it'd be like, you know, when emergency services is showing up at a building, and they've got a key code. They can punch into a lockbox on the side of the building to grab that key. So again, there's a scenario where, you know, extra keys are fine, just make sure you've got procedures in place, so you have control over those keys. And your idea with being able to recognize the cut, and that's great. That goes along the line of standardization. So, that's just another area that gives you some visuals for control. So, you asked an interesting question.
Jamie: Thanks, Bryan. A related question from Ken around the use of a group lockbox. He says using a group lockbox, what is the purpose of putting the keys for the lock inside if everyone on a work detail puts the lock on the group lockbox?
Bryan: Yeah, and I've ran into this too. It's, you know, it's your culture and your perspective. The deal of putting it all in one box, if you got one person overseeing it, he has a key to the lockbox, it's just another layer of control. I mean, this is from my opinion and experience. That's all I see. It's just it's just another layer of control. That being said, yeah, if you have, say, five people working on a piece of equipment, and they can each affix their lock to, you know, that device, then you're really covered as long as everyone's utilizing it. But even with that, if you've got several people, because again, there have been cases where people have not affixed theirs, it's a good idea to have still have someone with ownership of the entire process that's overseeing it. And lock box is just one way to make that happen. So again, good, good question.
Jamie: Yeah, thanks, Bryan. Let's see here. So, Neil has a question. Who can we engage to conduct a hazard assessment and program implementation?
Bryan: Okay, for this really, anyone that you deem has the knowledge. You know, with the equipment, I've dealt with mechanics who have worked on the same piece of equipment for a long time where they have a high mechanical aptitude, and I would deem them as definitely qualified to, say, put together lockout/tagout for that equipment. That being said, typically with new equipment or something you're installing or starting your program, you want someone that can verify they have the credentials to, you know, identify and give you a good level of confidence that your lockout/tagout program is effective, that they've actually copied, er they've actually captured all the different energy sources that could be inadvertently released — again physics, putting something into motion.
So, it would be like if you're doing, erecting a building, you want a structural engineer, you know. Same, you want someone that you can verify has the credentials that up your confidence level that everything's been captured, okay? So, again, it — I can't really think of a better way to say it than that.
As I said in the presentation, though, remember don't let this keep you from getting started. If you have equipment now that you understand, you know, here's the energy source, and we could do lockout/tagout now even though you don't have a program in place. Start doing lockout/tagout on that piece of equipment and build your program around it. You know, use that, go Nike on it and just do it. But you know, use the level of knowledge and expertise with the credentials to verify that you've captured all of the potential hazards. So again, I know it kind of rambled there but hopefully that helped you.
Jamie: Well, that's great. Thanks, Bryan. James had an interesting question. We did talk a little bit about the group lockbox he's asking, if you can just explain group lockbox use.
Bryan: Yeah, there's — the way I've seen it done, and again, I'm amazed at the creative way that the people apply different things, but typically you would have, say, your device. Or one reason also using a lockbox is if you have different lockout/tagouts going on at the same time. So, you have a maintenance program where you have, oh, go back to that lighting facility. We might have a team of, you know, 10 people across a production line all doing lockout/tagout. Well, if that maintenance supervisor or someone wants to really maintain good control of this, you know, when they do their lockout/tagout, again, they've got their lock and their tag that they put on their devices, they might put that, their key, what their destination. So, their name is on the key or whatever and goes in the lockbox. Then at whatever time, you know, when they're ready to bring it back up, again, it just gives them that other layer of control to the supervisor that, you know, “Hey, I know that Erica has done because she came and got her key. You know, I crossed her name off the list, and now I see that her device has been removed.” So, you know it's just another layer.
That being said, if, you know, as long as you're using everyone that's an authorized person is doing their lockout/tagout, you're being compliant. The others are just whatever fits your culture and helps you. I don't have a problem with it, and I’m actually trying to encourage redundancies at times. Just look at the potential for injury or for damaged equipment and how much control do you want to have. Again, if you have people that have been doing this for a long time that you got a high level of confidence in them, you got a strong safety culture, then that lockbox maybe is just not necessary at all. I would still have check sheets. I would still have someone that may be oversees it, but as long as they’re each using their lock and their tag, you're compliant.
Jamie: Thank you, Bryan. Alright, Shane has a question here. Who is in charge of spearheading lockout/tagout procedures on a job site?
Bryan: Good question. Now, and again, this kind of depends on your, your structure on a job site. It could be the supervisor, you know, a lead person, but it's someone that, you know… I talked about the what, where, how and why. If someone's been trained in all that, you know, that understands the importance, has the authority to oversee it and verify that everything's being done and being done well. There's a little bit more weight and burden that's being put on their shoulders. So again, if you're going to designate someone as responsible, again, you've got to make sure that they've been supported by the training, and they understand all the knowledge that they have to have to verify that, you know, the right processes have been followed to identify and follow, you know, all the lockout/tagout procedures, verify that all the energy sources have been dissipated, locked out and verified. So, really, it's up to you, as long as they've been properly qualified and are up to the task of the extra responsibility, then, yeah, you can choose.
Jamie: Great, thank you, Bryan. Alright, his is a question that came in before the webinar. So, let's just find it here. Dylan has a good question. Being in a municipality with a wide range of electrical exposures, how do you propose setting up the proper training that will cover everyone? So, it sounds like, you know, you're not just in one facility where everyone's just there. It’s in a municipality. So, can you talk a little bit about that, Bryan?
Bryan: Yeah, now, now you're getting a little bit more complex, but I've done a little bit with this, where you’ve… Okay, now you're, you're crossing paths with electrical workers, plumbers. There are lots of people with different skill sets. So, the main thing is ensuring the continuity, and all, everything still comes into play that I talked about in the webinar, in that, you know, your program has to be in place. You've got to have a way of deploying those three components, have your procedure in place, the training and then verification that everything is working.
So, as complex as it sounds, something that helps with this would be some software, you know, having something that you can use to track even though people are in different sites, different places, different times doing different activities. You need one database that you can go to, to look at, maybe from a standpoint of, you know what's going on this week, and you can actually go out and survey or have someone verify that what's being done, you know, what needs to be done is being done.
Even from a training standpoint, with that database, and knowing all the players, all the different people in their different fields, that you've got, you know, some verification that either they've been trained or you're going to provide the training. But a database where you have complexity of different time and different areas and different skill sets and different tasks. That software database would probably be your best tool to help you to wrangle that monster in where you've got kind of a one place that you can help to oversee and verify that what needs to happen to stay compliant is actually happening. That's about that, the best advice I can give because, yeah, that is a big monster, but it's one that still has to be wrangled in.
Jamie: Thank you, Bryan. Alright, Robert has a question here. Is minor servicing/adjusting allowed without lockout/tagout if interlocking guards are in place?
Bryan: Okay. Yeah, if you're dealing with any type of maintenance and production equipment, you're always going to end up at that question right there. And it still comes down to those two scenarios of, did someone have to interact with the equipment, and is there a guard off where they’re running. You said the guards are back on. So, if the guards are on, and then, yeah, you can bring the equipment up as long as no one's interacting with it. So, that means typically what I'll see as we’ll bring the equipment up, look at how it runs. If you need to use further adjusting, then you shut it back down, put your locks and tag back on, do your adjusting if you're removing the guards or whatever.
And again, this can happen fairly quickly, and it's just your culture you get used to, or using a job board or something to maintain control. But anytime you've got guards off where people are exposed to moving parts, you know, something you can grab and they're interacting with equipment, those are your signs that you still, you've got to have lockout/tagout because you're exposing someone to a risk, to a hazard. But yeah, you always find yourself at that point, that debugging. Well, you know, it has to happen.
Jamie: Thanks, Bryan. Okay, Peter thank you for your questions. I'm going to try and boil this down. I read them. I think I get the gist, but just let me know if I, again, I'm not articulating it properly. So Peter is asking about — and I've heard the word competent person or a qualified person for, for example, when you're working within the utility or an overhead line, you know, that's the linemen. So, as an example, and electrician wouldn't be the one, wouldn't be the qualified person. Can you talk a little bit about who would be the person to decide if something should be locked out and who should be the one to do it? I’m sorry, and who decides that the program is up to date or not?
Bryan: Oh, yeah. Good, really good question, and stuff that you don't want... Again, these are the things that keep safety people up at night if they think they don't have this hammered down. So, look to the industry standards for whatever it is you're working with. Like you mentioned, the line worker versus an electrician. And I've worked in the transformer industry, so I've got a little bit of experience at even dealing that.
The industry is going to dictate what they determine is qualified, and OSHA is going to go along with that, also. They're going to look at industry best practices. So, someone has to have the really not only proper training, but the certifications often if you're going to be dealing with electricity or high levels of electricity, or, you know, if you're taking, you know, that risk of hazard to higher level. I mentioned natural gas earlier. You know, when you're talking about dealing with ovens or fire, natural gas, you got a potential of explosions and some major catastrophes. So, the people that you've got working on systems, you know, have to have maybe certifications and a little bit more in-depth training to certify them as an expert for that field.
So, again, I know I'm probably not cleaning the water as much as maybe mudding it a little bit, but that's why certifications are there in industries to verify safety. I mean, that certification says that this person is trained and educated to the level of they can perform this work in a safe manner. So, whatever your industry standard is for the work they're doing, that's how you're going to have to look at it and apply it. So, you know, depending on the complexity of what you're working on and the level of danger provided, you know, again, we're talking about the catastrophe of an EPA oil spill or a gas leak that could cause an explosion. Yeah, most often you're going to need some certifications to help back the levels of expertise that you need for workers with those systems.
So, who is the person that would oversee that? Again, is someone that knows those regulations, or who has at least touched base with the regulatory agencies that verify that they're headed down the right path, that they got the right people with the right qualifications to do that work. So, the industry standards, my friend, are the ones that are going to point you into what direction you need to go.
Jamie: Thanks, Bryan. Peter, again let me know if I wasn't asking the question correctly.
Bryan: Yeah, you bet.
Jamie: It's hard to answer a question when you don't know what I’m asking about.
Bryan: You know, I love all… I love all these questions. Again, this is — that presentation, again, I really applaud National Marker Company. They put together a phenomenal presentation. This covered all the key points for lockout/tagout. And Jamie and I've had this discussion where complexity tends to lead to self-sabotage, where we avoid something if we see it as too complicated. And I think that's why a lot of companies kind of put off doing lockout/tagout. So, your questions, you know, if it helps improve your comfort level and get you down that first step, then this is fantastic.
Jamie: Yeah, I totally agree. I love that you kind of were mentioning there, you know, eat the elephant in in small chunks. Do it. Just do it, Nike. I really appreciate that, that feedback as well. Here's a question from Sarah. Are we supposed to lock out a machine that we aren't going to use anymore?
Bryan: If you're decommissioning it, taking it out of service, which usually means you would disconnect all power supplies, all feeds to it, something like that, then no. As a matter of fact, lockout/tagout is for things that are in service or can be put into service. So, once you decommission equipment, it kind of goes under some different protocols. But what I would suggest is you make sure that you've got a program and procedure in place to handle the decommissioning of equipment to where, again, you verify that you've disconnected all energy sources, and you've got a way of handling that. So yeah, you don't use lockout/tagout on equipment that you're not going to use anymore, but you've got other protocols to make sure that, again, energy has been dealt with, and they've all been disconnected.
Jamie: Great. Thanks, Bryan. Okay, Hasan says, “Do authorized employees have to be trained to do all of the machine specific procedures for all the machines in a facility, or can they just be trained on the procedures they do for their job?”
Bryan: What a what a good question. I've seen companies not understand this and start to go to down that path and try to train everyone for everything. Yeah, that doesn't work. Remember that, you know, we all go with that our favorite radio station is What's in It For Me. So, we got to understand that why before we go for the how. So, having people learn equipment that they're not going to have to work on or do lockout/tagout on is kind of a burden for them and a waste of time, and it really muddies the water for the stuff they will have to do lockout/tagout on. So, specialize.
This is what I meant by in the program where we talked about changes of personnel. So, you need to train people to be authorized for the equipment they're going to work on, that they'll have to do lockout/tagout on. So, Jamie works in one area, and he's going to be transferred to another area where he's got to work on different equipment. Now you're going to train them to be authorized for that equipment. So yeah, keep it specific. Don't overburden people unnecessarily. So again, good question.
Jamie: Great answer. Thank you, Bryan. Alright, Ernest has a question. Is a disconnect lockout sufficient or do you need to go back to the actual breaker?
Bryan: In most places that — and this is in my opinion — you want to do your absolute best to make sure you've got the hazard in control. So, if it's something you can unplug and put a lockbox on that device, on that plug, then you're covered, you're fine. There's no real need to lock out that breaker. But if this equipment that you can't, say, unplug, you know, it's connected to it, you know, you might lock out a switch on there. But in cases like that, I've gone ahead and had them lock out the breaker also. So, again I kind of go with best practice. So, yeah, if you can unplug it, put a lockout device on the plug itself, you know, on the cord, there's no need to worry about that breaker. But if it's hardwired, then locking up the breaker is probably a good idea.
Jamie: Alright. Alright, looks like we’re about three minutes to the top of the hour. So, if you've got a question that you want to get in, now's that time. Claire has a question. Should tag — oh, sorry. Should tagout tags be a bit larger depending on people's eyes? So, I don't know, Bryan, if you have any experience with what's that.
Bryan: Good. Good question because actually, again, the idea of the tag, part of the purpose is to give the information of, you know, who put it on there, but also to grab your attention. So, you know, depending on your environment, if those tags are hard to see, you don't want — if people have to look for the tag, then there's a problem. You want that tag basically waving its hand and grabbing people's attention. So, yeah, depending on your environment, if they're hard to see, yeah, I'd go for a little bit bigger tag. That's a great idea.
Jamie: Great. Thank you, Bryan. Let's see here. So, Chris if you're still on the line here, Chris has a question or before the webinar. He says, “How effective are permits? How to hold someone and who to hold accountable?” So, maybe you talk a little bit about, you know, if something does go wrong and you've got that permit in place and maybe the lock is there. Talk about a little bit about accountability if you can.
Bryan: You bet. And actually, that's a great question because, you know, in many cultures depending on what you're using, we're used to permits. We use, you know, confined space entry permit, hot water permit. Remember, a permit is basically just a check sheet that, and also gives some ownership and some accountability and provides a record. So, that's why we do permits. Well, you know, when it comes to lockout/tagout, like I mentioned before having a log book, you want the same components. You do not want the honor system. So, you know, it's not necessarily a permit, but you're going to have those same characteristics as a permit.
So, what I would recommend is, you know, for each lockout/tagout, they have a check sheet they follow, and maybe a log book that they sign. A permit is fine. Again, go with your culture. The purpose of those permits are: they provide a check sheet, they provide ownership, you know, if someone's filled it out, they're more likely to follow it, and it provides a record that it has actually been done. So, yeah, I would go for not necessarily the permit, but make sure your lockout/tagout has those same characteristics.
Jamie: Great. Thank you, Bryan. Alright. Looks like this will be our last question as we approach the hour. Smart has a question. It says, “Can I write on the padlock with my information on which other colleagues can read?”
Bryan: Interesting question. Typically… I mean, there's — I don't know if any regulation that says, you know, you couldn't do it other than, you know, the standardization feature. Typically, your information would go on that tag. That being said, if you need some identification on the lock, again, I see it as additional information. As long as people are trained to understand to look for it, I don't see a problem with it. That's interesting. You kind of stumped me on that one. Again, my opinion would be use a tag to the best of your ability, but I don't see any harm as long as you can be consistent with that information, and people are trained to look for it and add it.
Jamie: Well, personally, I'm going to send Smart a prize pack. Somebody is finally stumped Bryan. It’s music to my ears.
Bryan: They got me.
Jamie: Thank you. We need we need more of those. Come on. Alright. Well, we're right at the top of the hour. Bryan, any, any parting words before we close the webinar?
Bryan: I just want to thank everyone for participating and encourage you, if you do not have a program, again, look at that hazard assessment. You know, pick some equipment and go all Nike on it, then start building your program. It's hard to defend no activity at all, but once you start, you know, again, that journey of a single, of 100 miles, begins with a single step. So, you know, start your steps.
Jamie: Thank you, Bryan. Yeah, and I I'd like to thank Bryan for delivering a great presentation. I know you put a lot of time into this. National Marker, everybody there, Erica, Ashley, the whole team. You know, without you guys, this whole thing couldn't have come together. So, great job. I know it’s a lot of hard work, but I think it really shows the value that this presentation is giving just from an educational aspect. Great job putting it together and thank you so much for sponsoring the webinar. But especially the audience. Without you guys, you know, we'd be just talking amongst ourselves. We very, very much appreciate your attendance, your registrations, your questions, great questions. You know, you’re really helping us keep all of this information free to the public, so we're extremely grateful. We thank you for your time. We know you have a choice of where to spend it, and we're extremely grateful that you're spending some of that with us.
So again, everybody, we will be sending out a link to the recording and the presentation slides in just a few days. And with that, we'll close it out. So, thanks, everybody. Take care and stay safe.