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Corey Brown

Operations

How to Write Better Lockout/Tagout Procedures

Protecting your most valuable assets

Published: Tuesday, January 26, 2021 - 12:03

Lockout/tagout (LOTO) procedures are common in industrial and manufacturing environments. Despite this, failure to adequately train employees on LOTO procedures continues to be one of the U.S. Occupational Health and Safety Administration’s (OSHA) top 10 most frequently cited violations during federal inspections.

To write an effective LOTO procedure requires both an understanding of OSHA’s guidelines, as well as good communication and training practices. By combining these strategies, manufacturing companies can ensure the health and safety of their workforce while maintaining operational efficiency.

What is a lockout/tagout (LOTO) procedure?

LOTO programs require that all sources of energy are controlled during any servicing or maintenance of a machine. The OSHA lockout/tagout standard (29 CFR 1910.147) provides clear requirements for creating and training employees on safety standards. Properly documenting these procedures is required by OSHA to ensure that machinery is safely turned off and locked or tagged.

According to OSHA’s guidelines, lockout/tagout programs consist of any specific procedures designed to, “safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.”

A “lockout” procedure ends with the use of a locking device, which ensures the machine remains in the safe or “off” position unless a key or extreme measures (like a bolt cutter) are used to unlock it. In contrast, a tagout procedure ends with a tag fastened to the machine, warning employees to not turn on the machine.

OSHA’s lockout/tagout procedure guidelines:
• Notify all affected employees.
• Shut down the machine.
• Disconnect or isolate the machine from the energy source(s).
• Apply the lockout or tagout device(s) to the energy-isolating device(s).
• Release, restrain, or render safe all potential hazardous, stored, or residual energy.
• Verify the isolation and de-energization of the machine.

Tips for writing better LOTO procedures

At Dozuki, we specialize in improving communication and employee performance. After working with hundreds of customers, we’ve learned how to write better procedures and work instructions that have huge impacts on quality, safety, and employee performance.

Clearly define safety equipment
Define your safety equipment and personal protective equipment (PPE) in your LOTO documentation using visuals. OSHA specifies that any required safety gear and PPE be defined clearly and that the employee is provided proper training to use said equipment.

This is where companies sometimes make dangerous assumptions. Not everyone knows how to use a torque wrench. Don’t assume the skill or knowledge levels of your employees.

Identify LOTO devices with visuals
Illustrate the location of all LOTO devices using images or videos. Industrial machines, circuit breakers, plugs, switches, push buttons, and valves are just some of the items that often require lockout and/or tagout devices.

Clearly communicate these items in your written procedures by including images and detailed descriptions. One study found that groups following specific technical procedures performed 65-percent better when following material with visuals. Text-only work instructions are insufficient when it comes to essential processes. Your employees deserve better.

Use direct and concise wording
Lockout/tagout procedures aren’t suggestions; they are meant to be followed. Use the active voice by starting all sentences with a verb. This approach immediately sets the stage for the “who” and “what” of the procedure. As a result, employees clearly understand what is expected of them.

To further improve clarity, say what you mean without wishy-washy words. Words like “mostly” “slightly,” “seems,” and “somewhat” are built-in loopholes. Avoiding these words give your instructions more authority and clarity.

Record verification methods
When a machine has been de-energized, operators must verify that the machine will not turn on or re-energize. This is typically done by attempting to turn the machine back on or checking indicator readings.

Record successful lockouts and note if anything was different or challenging. This system of record is invaluable for troubleshooting future incidents and identifying areas for improvement.

Many times documentation only informs on how to perform a task if everything goes well. Unfortunately, this isn’t always the case. Where most LOTO procedures fall short is in their ability to solve problems.

Although it can become an information overload to include solutions for all possible scenarios, connecting your LOTO procedure to essential troubleshooting information can save thousands of dollars in unplanned downtime and quality costs.

Use modern tools to notify affected employees
Before beginning any lockout/tagout procedure, operators should notify all affected employees that the machine will be shut down and locked out to perform service, maintenance, or a changeover.

In your written procedure, specify who needs to be notified and clearly describe how to notify said employees. Digital tools have an advantage here because they can communicate notifications instantly and ensure that you’re reaching the right people.

Good procedures are accessible procedures

It doesn’t matter how well you write your lockout/tagout procedures if your employees can’t access them. Finding the proper LOTO information should be simple and intuitive.

Traditional stacks of paper binders no longer meet the demands of the modern manufacturer. Use a digital system that prioritizes ease of use and accessibility. This will ensure that the LOTO procedures are used, provide adequate training, and are always up to date.

First published on the Dozuki blog.

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About The Author

Corey Brown’s picture

Corey Brown

Corey Brown is the lead researcher and editor for manufacturing resources on Dozuki.com. With a background in engineering and technical communication, Corey specializes in quality management, standard work, and lean manufacturing.

Comments

A very important topic

Lockout/tagout exemplifies what was called "Can't rather than don't" at the Ford Motor Company almost 100 years ago. The idea is that, instead of telling workers "Don't turn on the machine when somebody is working on it," you lock out all the electrical and mechanical energy sources so they can't turn on the machine. As the author points out, however, this is among the most frequent OSHA violations and a tuna worker was killed not that long ago as a result of the oven he was working on not being locked out. https://www.nbcnews.com/news/us-news/bumble-bee-foods-2-managers-charged... This should have been easily preventable through the techniques discussed in this article.

I shared the link to this article on LinkedIn and it is well worth reading.

Thanks for sharing!

Thanks for sharing your insight and that example, William. It's unfortunate to hear of those preventable incidents and hopefully, the industry can continue to evolve in the right direction. "Can't rather than don't" is a great way to put it!

It's clear that OSHA fines only go so far as to incentivize good practices. I'm curious, from your experience what are the most common reasons companies fail to establish/maintain more effective LOTO procedures?

I don't know why LOTO is not used more widely

It is one of the most commonly cited OSHA violations. It's possible that pure ignorance is involved, and/or people don't want to take the time to do it right. If done properly, though, it can make safety incidents close to impossible. A machine with zero electrical and mechanical potential can't do much of anything to anybody.