What is the most overlooked item when designing Lockout/Tagout (LOTO) procedures?

Lockout/tagout (more commonly known as LOTO) procedures are processes that are put in place to keep workers and others safe during equipment maintenance and repair. These procedures ensure that equipment is turned off and cannot be restarted (either accidentally or intentionally) while repairs are ongoing (read more in Understanding Lockout/Tagout Safety).

The Occupational Safety and Health Administration (OSHA) has designed and established stringent LOTO procedure guidelines; these guidelines were originally drafted in 1982 and were put in place in 1989. These procedures provide employers with a degree of flexibility based on the individual industries that they operate in. They cover electric-powered equipment, which accounts for a significant percentage of all injuries, and they also apply to equipment powered by alternative sources, such as pneumatic and hydraulic equipment.

OSHA and other regulatory agencies estimate that LOTO procedures effectively protect up to 3 million American workers. OSHA also suggests that poor application of LOTO procedures, coupled with human error and negligence, account for a myriad of injuries each year. Many of the resulting injuries are quite serious. Evidence indicates that, on average, an injury resulting from a LOTO protocol breach causes 24 days of lost work per affected employee.

In addition to the above-mentioned procedures, OSHA also stipulates that all potentially impacted employees must be adequately trained on LOTO protocols and procedures. It is not enough to simply have OSHA-compliant procedures in place; instead, these policies have to be put into practice on a daily basis. This is something that is frequently overlooked or glossed over by employers and employees alike who do not want to devote time to things that seem like common sense. This is particularly true when it comes to mandatory re-training and updating employees on new equipment and protocols (read more reasons to Invest in Employee Training). The cavalier assumption that people know what they are doing puts lives in danger. There is also extensive anecdotal evidence indicating that even employees who have worked for years at the same facility cut corners in an attempt to save time.

Actively working to minimize the potential for human error and underscoring the importance of effective training programs are the most overlooked aspects of LOTO programs across all industries.