Individual Lockout Tagout (LOTO) for machine maintenance and repair is highly standardized. However, the complexity increases when involving a group of employees, potentially across multiple machines, departments, crafts, and shift changes. The risk of accidental re-energization rises, necessitating additional protective measures. Therefore, the Occupational Safety and Health Administration (OSHA) mandates enhanced coordination and communication for group LOTO, specifically outlined in 1910.147(f)(3).
Here we will explore the specific aspects of the OSHA standard as it pertains to group lockout procedures and policies, addressing common challenges, best practices, and effective devices for implementing a group lockout box procedure.
Lockout Tagout by the Numbers
Approximately 3 million workers in the U.S. service machinery and equipment, facing risks from accidental release of stored energy. The OSHA standard, Control of Hazardous Energy (Lockout/Tagout) 29CFR 1910.147, outlines necessary practices to prevent such incidents. This standard consistently ranks in OSHA’s top 10 most cited categories, placing 4th in 2018 and 2019, and 6th in 2020 with 2,065 violations. Despite its complexity, it helps prevent an estimated 50,000 injuries and 120 fatalities annually.
Specifics of Standard 1910.147 for Group Lockout
Section 1910.147(f)(3) addresses group lockout procedures, crucial when multiple energy sources, crews, crafts, locations, employers, or disconnecting means are involved, during shift changes, or when a specific sequence of operations is necessary for safety.
- Designating a single responsible employee for overall procedure accountability.
- Ensuring each authorized employee applies their own padlock to isolation points.
- Including work authorization permits in written procedures when required.
Common Group Lockout Tagout Challenges
1. Working Under Someone Else’s Lock
- Employees servicing equipment under another’s lock operate under a false sense of security, risking accidental re-energization. Each worker must apply their own lock to ensure compliance with OSHA’s “one person, one lock, one key” rule.
2. Being Unprepared
Lack of proper lockout devices wastes time and increases risk. Teams should be well-prepared with necessary locks, tags, and devices, and regularly review procedures and training. Always use a hasp, and add additional hasps or use a group lockbox to avoid using the last lock position.
3. Lack of Coordination and Oversight
- Effective coordination is crucial, as outlined in OSHA 1910.147(f)(3)(ii)(C). Use group lock boxes, sign-in/out sheets, and ensure clear display of procedures. Daily facility checks by shift supervisors or maintenance leads can help identify issues.
4. Abandoned Locks
- Abandoned locks slow operations and increase risk. Ensure all workers remove their locks at the end of their shift to prevent this problem.
5 Best Practices for Successful Group Lockout
1.Develop a Written Group Lockout Program :
- Make it company- and site-specific, including procedures for contractors, shift changes, emergency lockout removal, and assignment of responsibility. Inspect annually, aligning with low production periods or regular events.
2. Perfect Your Padlocks
- Use durable, standardized, identifiable locks and tags exclusively for hazardous energy control. Color-code for departments and groups, organize key systems, label tags with employee details, and use reusable laminated tags for employees and disposable ones for contractors.
3. Structure Shutdown and Startup
- Perform a scope of work, conduct a job safety analysis (JSA), and document shutdown/restart processes. Ensure procedures are requested, developed, reviewed, and approved.
4. Make Information Accessible
- Label isolation points, use sign-on/off forms, and document lock box locations and procedures. Utilize software like Brady LINK360 for visual lockout procedures and forms, linking to barcodes for easy scanning and verification.
5. Manage Workers and Shift Changes
- Use clear labels and colors for managing workers and shifts. Employ a red lock box for employees and a yellow one for contractors, ensuring the coordinator’s lock is first on and last off. Assign shift coordinators to track progress and handle lock removals, providing proper training for new staff.
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