The Myths Of Lockout/Tagout – Part 2

Myth: Each machine specific procedure must contain lots of detail

OSHA: OSHA concurs with those commenters who stressed the need for flexibility in the standard. For example, the detail into which a procedure may have to go may vary depending upon the type of power the machine or equipment may utilize, or the means used to isolate or block the machine or equipment from the source of power…

 However, whereas the procedure is required to be written in detail, this does not mean that a separate procedure must be written for each and every machine or piece of equipment. Similar machines and/or equipment (such as those using the same type and magnitude energy) which have the same or similar types of controls can be covered with a single procedure.

The written energy control procedure required by this standard need not be overly complicated or detailed

Myth: I’m a lot safer and more compliant if I require Lockout, even for Minor Servicing tasks

OSHA: There are some activities which are properly classified as servicing or maintenance but which are often performed during normal production operations. These activities include lubricating, cleaning, unjamming, and making minor adjustments and simple tool changes. In the proposed standard, OSHA suggested excluding these operations (paragraph (a)(2)(iii) stated, `when it is necessary to perform the activity and if the activity is performed using alternative measures which the employer can demonstrate are equally effective’).

Myth: OSHA does not recognize any alternative procedures to Lockout

OSHA: OSHA recognizes that some servicing operations must be performed with the power on; in these situations, it would not make sense to require lockout or tagout, which apply to deenergized equipment. The proposal contained a requirement that when servicing or maintenance must be performed with the equipment energized, the employer must use an alternative procedure which provides, in the language of the ANSI standard “effective protection.”

Myth: We must always shut down primary power for Lockout

OSHA: In the case of required minor adjustments where this (deenergization) is not feasible, or in the case of normal production operations, these activities shall be accomplished under the protection of specially designed control circuits, control equipment, and operating procedures, that provide proven effective protection for the affected personnel.

Myth: ANSI standards are not regulation; hence they have no value for compliance

OSHA: The concept behind both the proposed and final provisions on normal production operations was taken from the ANSI standard, which attempted to address situations in which it was necessary to keep equipment energized during servicing. It was clear to the ANSI committee, as it was and is to OSHA, that neither lockout nor tagout is possible in a situation when the equipment cannot be deenergized, because these efforts involve assurances that deenergization has been achieved and that the proper procedures and verifications of deenergization have been carried out. However, both ANSI and OSHA believe that even if lockout or tagout cannot be done, the employer must provide alternative measures to lockout/tagout which will protect the employees doing the servicing under those conditions.

Myth: My annual inspection must happen during a given period each year

OSHA:   One method for meeting the performance requirements in this paragraph would be to use random audits and planned visual observations to determine the extent of employee compliance. Another would include modifying and adopting ordinary plant safety tours to suit this purpose.

Myth: Training for Affected Workers cannot take the form of supervisor instruction or a Toolbox talk

OSHA: The training OSHA requires for “affected employees” is less stringent than that for “authorized employees,” simply because affected employees do not perform servicing or maintenance operations which are performed under an energy control procedure…..The instruction needs to be sufficient to enable the employees to determine if a control measure is in use.

Myth: All energy sources must have individual labels

OSHA: OSHA has determined that the marking or labeling of energy isolating devices is not reasonably necessary for the effectiveness of the energy control program. Authorized employees are required at (c)(7)(i)(A) to receive training in and to know that information relating to hazardous energy.

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OSHA Clarifies Drug Testing, Incentives

Agency Says Post-Incident Drug Testing, Safety Incentives OK

Good news: OSHA is pulling back its previous stance on safety incentive programs and post-incident drug testing – the guidance that left many safety pros confused. OSHA issued anti-retaliation guidance in 2016 that gave examples of safety incentives and post-accident drug testing as unlawful retaliation. The agency’s stance was safety incentive programs that rewarded employees for time periods without injuries, and blanket post-incident drug testing, could discourage workers from reporting injuries.

Memo reverses OSHA’s stance

A newly released OSHA memo intends to “clarify … that (the agency) does not prohibit workplace safety incentive programs or post-incident drug testing.” Post-incident drug testing and safety incentive programs will only be considered retaliatory when they seek to penalize a worker for reporting a work-related illness or injury. Bottom line: If you follow a few basic guidelines set by OSHA, you can still have incentive programs and post-incident drug testing without fear of facing OSHA citations.

Remember the small print

OSHA says, “most instances of workplace drug testing are permissible.” That includes testing to evaluate the root cause of workplace safety incidents. The caveat: Testing must be conducted consistently on any worker whose conduct may have caused the accident, not just the worker who was injured in the accident. OSHA now also permits safety incentive programs that offer a prize or bonus at the end of an injury-free month or time period. However, employers must use “adequate precautions” to ensure workers feel free to report injuries. Precautions include adding features to a program like rewards for workers who identify unsafe conditions, training that emphasizes anti-retaliation policies and evaluating workers’ willingness to report injuries.

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The Myths Of Lockout/Tagout – Part 1

Myth: I have to lockout energy whenever I do any service or maintenance

OSHA: When such servicing may expose the employee to the unexpected activation of the machinery or equipment, or to the release of stored energy, this Final Rule will apply.

Myth: There is no alternative to lockout when doing service and maintenance

OSHA: …lockout or tagout is not required by this standard if the employer can demonstrate that the alternative means enables the servicing employee to clean or unjam or otherwise service the machine without being exposed to unexpected energization or activation of the equipment or release of stored energy.

Myth: My workers insist they need power, but we have a zero tolerance policy on doing lockout

OSHA: The Agency recognizes that there are certain servicing operations which, by their very nature, must take place without deenergization

Myth: It is not necessary to consider exposure to a hazard when requiring lockout.

OSHA: Some servicing operations do not expose employees to hazards which would necessitate that a machine, equipment or process be deenergized and locked out or tagged out…

If no such exposure will occur, either because of the method in which the work is performed or because special tools, techniques, or other additional protection is provided, lockout or tagout is not requiredIf there is such exposure, the lockout or tagout requirements of this standard apply. However, if the servicing operation is routine, repetitive and must be performed as an integral part of the production process, lockout or tagout may not be necessary, because these procedures would prevent the machine from economically being used in production.

Myth: Lockout must be done, even if it is not feasible

OSHA: Based upon an analysis of the rulemaking record, OSHA believes that the safe performance of activities such as repair, maintenance and servicing, requires the deenergization of machines or equipment whenever feasible.

Myth: Use of a lock is the most important issue to comply with CFR 1910.147

OSHA: It should be noted that locks and tags by themselves do not control hazardous energy. It is the isolation of the equipment from the energy source and the following of the established procedures for deenergization and reenergization of the equipment that actually controls the energy.

Myth: CFR 1910.147 does not apply to process safety management

OSHA: However, the Agency considers the basic approach of this standard to be appropriate for the control of all hazardous energy sources, including those discussed by API. (American Petroleum Institute)

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How Can Businesses Eliminate Worker Injuries to Reach a Goal of Zero Incidents?

 

 

 

 

The Zero Incidents Vision

Over the years, businesses have implemented many unique procedures and policies to eliminate worker injuries and workplace incidents. Today, Health & Safety professionals are promoting Zero Incidents as the benchmark for safety management excellence.

A Zero Incidents goal aims to eliminate all events that result in injury, property damage, and have the secondary consequences of:

  • Damaging your brand.
  • Prompting legal action.
  • Halting production.

This Zero Incident philosophy is somewhat polarizing, with some safety professionals who perceive Zero Incidents as the new standard and others who say it is an unrealistic goal. Regardless of whether you’re aiming to reduce your reportable incidents to zero or just reduce your overall incident count, this article will outline some of the fundamental processes that need to be in place to achieve your health and safety goal.

The Journey to Zero Incidents Requires Training

The most proactive way to achieve Zero Incidents is to train your workers—there is a measurable relationship between the amount of pre-emptive training you deliver to employees and the rate of workplace incidences. It’s no secret that staff given proper training about a process and its safety measures are significantly less likely to experience an incident or injury.

However, it’s not enough to simply give good training to your team; these efforts are only effective when you closely monitor employee training performance with the aim to continuously improve the safety record of your organization. Zero Incidents as a target creates the necessity for efforts to establish better management and procedures for training. Being able to create more effective training programs to combat common incidents for your workplace means having an understanding (and way of measuring) both your leading and lagging indicators.

Leading indicators are the measurable factors that contribute to the root cause of an event and can help predict where and when an event is likely to happen – for example, was the employee trained in safe operating procedures, and what safety audits did you do before beginning work? Lagging indicators are the measurable details of an incident that can be observed after the fact, including the type of injury or number of hours of process shut down.  Businesses can use lagging indicators to create a baseline to assess management training practices to make improvements. On the other hand, leading indicators focus on future health and safety outcomes with the goal of improving overall safety and reducing injury. Health and safety managers use leading indicators to create new procedures and monitor compliance and lagging indicators to adjust activities and training to avoid injury and reach the goal of lower incidents.

Being able to measure and compare leading and lagging indicators is essential for building a better training program and getting on track to reach a Zero Incidents goal. Some indicators you should monitor include:

  • Employees taking training compared against employees involved in incidents.
  • Rate of refresher courses versus rate of incidents (per process type).
  • Employee wellness programs (for example, ERA provides our staff with an employee gym for physical health and ergonomic sit/stand desks).
  • Frequency of safety audits against near misses.

It is important that businesses aim for proper training and fewer incidents without pressuring workers to under report minor injuries. In aiming for fewer incidents, one should also create a workplace culture that is open to (and potentially rewards) reporting from employees rather than an atmosphere of fear and silence. Incentives for training, such as bonuses for employees who participate in safety programs, can promote a no-incident culture by promoting workers who prioritize safety. OSHA’s VPP Guidance materials suggest several positive incentives offering modest rewards for successful company-wide safety and health training. Zero Incidents serves as an opportunity for businesses and employees to learn how to achieve the highest results in workplace safety.

Benefits of Risk Assessments and Root Cause Analysis for Employers

A risk assessment involves the process of evaluating risks to workers’ health and safety from workplace hazards. Risk assessment plans collect vitally important information which can be used to create a no-incidents culture for workers. A proper risk assessment methodology aims to identify:

  1. Hazards that have the potential to harm any person at a facility.  This process, known as hazard identification, consists of recording actual physical hazards that can take any number of forms – from fall hazards, to proximity to dangerous machinery, to injuries from carrying heavy objects, etc.
  2. The actual level of risk posed to staff and site visitors by any identified hazard, a process commonly referred to as risk analysis.
  3. Risk evaluation levels or ascertaining the significance of the risk in a broader context.  

Health and Safety managers should combine a risk assessment with a root cause analysis to eliminate workplace hazards and achieve low incidents. The Occupation Safety and Health Administration (OSHA) defines a “root cause” as “a fundamental, underlying, system-related reason why an incident occurred, that identifies one or more correctable system failures.” OSHA explains that “by conducting a root cause analysis and addressing root causes, an employer may be able to substantially or completely prevent the same or a similar incident from recurring.”  Employers conducting a root cause analysis seek to discover the underlying and systemic causes of an incident that will help prevent similar events from happening again rather than simply correcting the problem itself. In taking actions to identify and correct underlying system management shortfalls, employers can avoid unnecessary fines and litigation.

Interviews, checklists, event trees, and other tools assist employers in identifying root causes for incidents ranging in complexity. A root cause analysis combined with a risk assessment creates a clear, guided course to the goal of less incidents. Employers benefit from reduced failures and prevented incidents resulting in improved process reliability, increased revenues, decreased production costs, lower maintenance costs, and lower insurance premiums.

Conclusion

The most successful improvements in health and safety are based on training and measurements of risk assessments and root causes. Risk assessments and root cause analyses serve to provide “early warnings” about potential hazards to avoid incidents. Once issues in your process are uncovered, training staff on the new procedure is the best way to zero incidents. Zero workplace incidents can be achieved once companies invest time and resources in the right processes.

The aim for zero represents perfection, however employees cannot operate perfectly all the time. Zero is rather a target for employers to demonstrate commitment to reducing workplace incidents to achieve safety for everyone. Employers work alongside employees to reach safety goals; however, employers send the message through company health and safety goals to communicate that incidents are not acceptable. Rather than a numerical goal of zero, Zero Incidents allow companies to show their underlying philosophy—that safety must be emphasized and that human life and injury is of the highest priority.

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