Session T06 Lock out Tag out Juan Jane Mark

Session T06 Lock Out Tag Out Juan Jane Mark

Three Safety Professionals Their plans for LOTO implementation and program efficiency

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 2 Juan’s Bio . Plant Manager – Water Treatment Facility . Responsible for one facility . Simple equipment, many identical units . Limited resources available to support program . Minimal existing LOTO Program . Generic written program rules . Non-standardized procedures for a few machines . Employees understand LOTO, but don’t know when to use . Goals – Basic compliance . Documented processes for improved safety . Simple process to implement program

Juan

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 3 Jane’s Bio . EH&S Manager – Food & Beverage . Responsible for medium sized facility; goal to expand program to 5 other plants . Filling & packaging lines, mixing rooms, facility equipment . Knowledgeable team members, too many corporate initiatives . Outdated LOTO Program . Facility has expanded, lots of construction, difficulty managing program . Some policies and procedures . Annual safety trainings for all employees . Goals – Industry best practices . Going to redo entire program, done the right way . Need buy-in with employees and other sites

Jane

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 4 Mark’s Bio . Corporate Safety – Automotive Plant . Responsible for large facility . Safety is a big focus . Software for developing LOTO . Documented procedures for all equipment . Tied to PM software for regular program inspection . Well used, not well maintained program . Goals – Program optimization . Small improvements, quicker time to lockout . Increase productivity, expand program with additional safety procedures . Easier program management

Mark

BARRIERS GOALS  Knowing where to start  Basic compliance  Program development  Simple implementation  Final implementation  Best practices  Approvals  Modernization  Time and resources  Company-wide buy-in  Ownership  Program usability  LOTO Knowledge

Simplification is key. A program must be simple to implement, simple to use, and simple to maintain

To achieve program adoption, you must consider your people

It is not enough to be safe, you must also be productive

PUBLIC

. “This standard applies to the control of energy during servicing and/or maintenance of machines and equipment… Normal production operations are not covered by this standard.”

. “The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections”

. “Locks, tags, or other hardware shall be provided by the employer.”

Lockout/Tagout Written Policy Juan’s Goal: Compliance with regulation

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 9 Developing a Written Policy . Defined scope of program . Servicing & maintenance activities . Bypassing guarding, putting body in harm’s way . Definitions for: . Service, maintenance . Lockout, tagout . Authorized employee, affected employees, contractors, visitors . Provisions for: . Documented LOTO procedures . Authorized and affected employee training . Locks, tags, and devices . Annual inspection . Program responsibilities and ownership Lockout/Tagout Written Policy Juan used a policy template and made simple changes to customize

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 10 Considering People . Reviewed existing policy for employee usability . Understand rules and gaps . Feedback from EHS team . Talked to employees to gauge their understanding & questions . Findings: . Unclear program ownership amongst management . Too many steps to update procedures, too hard to make changes . Questions from authorized employees, processes not documented

Lockout/Tagout Written Policy Jane’s Goal: Make the policy applicable for entire team

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 11 Improving Written Policy with Users in Mind . Defined responsibilities and ownership . Who develops new procedures . Who trains employees . Annual program inspection plan . Eliminated redundant approvals . Streamlined process to develop and implement new procedures . One knowledgeable approver for updates . Documented specific processes . Shift change . Lock removal

Lockout/Tagout Written Policy Jane reviewed policy to understand what employees and managers needed

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 12 Reviewing for Efficiency and Clarity . Reviewed employee understanding of the policy . Employees did not have access . Did not know purpose of policy . Contractor work . Didn’t know which procedures to follow . Risk of contractors locking out incorrectly . Minor servicing . Realized many LOTO tasks were minor and repetitive . New equipment & line upgrades . Difficult to track when procedures needed updating . New equipment not designed for most efficient LOTO

Lockout/Tagout Written Policy Mark’s Goals: Enhance the program, clarify policy, tie-out with other policies

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 13 Policy Additions to Minimize Risk and Save Time . Made LOTO policy accessible on shared drive . Working with contractors . Documented process for working with contractors . Company maintenance person in charge of LOTO and contractors . Developed minor servicing exception policy and procedures . Saved time for minor, repetitive tasks done frequently, where applicable . Documented and assessed for risk before implementation . New equipment & line upgrades . Designed with LOTO in mind

Lockout/Tagout Written Policy Asked employees for input on how LOTO program could be more effective

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 14 Benefits from program updates . Minimize downtime . Alternatives for minor servicing tasks . Local disconnects . Minimized risk . Unknowledgeable contractors . Risk assessments . Documented information . Clarification . Less questions on processes

Lockout/Tagout Written Policy Added policies for contractors, minor servicing, and new construction

. Every company must have a written program for lockout/tagout . Do you have a written policy? . Has it been reviewed recently for possible improvements?

. How could you update your policy to better benefit your people? . All processes and rules related to LOTO must be documented . The policy should be a reference for LOTO-related questions

. Do you have the right people for each responsibility of the program? . Is there someone in charge of training? Procedures? Audits? . Ensure it’s clear in the policy who’s in charge of what

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. “Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy”

. “Specific procedural steps for the placement, removal and transfer of lockout devices”

. “Verify the effectiveness of…energy control measures”

Lockout/Tagout Procedures Juan’s Goal: Develop basic, compliant LOTO procedures

. Developed basic LOTO Procedure . Generic procedure for each type of machine . Statement for use . When LOTO is required . Steps for control . Notify employees . Shut down machine . List of energy sources . Steps for verifying the lockout . Attempt to restart . Dissipate residual energy

. Easy, quick to develop . Minimal useful information . No visuals . Specific valves and disconnects not identified . Format difficult to follow . No information on devices to use . Possible compliance issues . Missing specific methods for isolation . Magnitudes and other information on hazards . Missing specific means of verification

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 20 Decided to Invest in Outside Consultants . Wanted the program done correctly . In-house resources were less familiar with LOTO . Guaranteed compliance with 1910.147 . Unsure of best practices . Limited resources available to complete in house . Able to start project quickly and complete within weeks . Looked for options for scalability . Ability to maintain program in-house, as well as develop additional procedures . Needed a custom solution . Wanted to expand program to other facilities . Usability for authorized employees

Lockout/Tagout Procedures Jane’s Goal: Follow best practices, repeatability at other facilities

. Easy to use format, quick to pull information . Photos of isolation points for clarity . Color coded by energy source type . Matching isolation ID tags . Ensure correct energy source locked out . Minimized risks . Location, device type, associated hazards & magnitude . Methods for controlling each energy source . Verification steps . Residual energy and methods for dissipation noted

. Quick turnaround time for program completion . LOTO experts . Knowledgeable on OSHA and regulation . LOTO best practices . Specialized consultants . Minimal internal resources utilized . Ability to own the program long-term . Support on other aspects . Employee training . Policy review . Device recommendations . General consulting, Q&A

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 23 Part 1: Usability & Productivity . Already had LOTO procedures . Looked at making the lockout process faster . Looking at the equipment: . Installed local electrical disconnects . Relocated valves to be accessible . Upgraded valve to accept padlock, eliminating need for devices . Looking at program: . Relocated procedures to be hung at the point of use . Developed means to notify EH&S when new procedure needed . Shared Inbox

Lockout/Tagout Procedures Mark’s Goal: Find improvements to minimize downtime & increase productivity

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 24 Part 2: Modernization . Solution . Tablet-based program management system . Procedures & documents stored on cloud . Lockout usage tracking, program management . Easy Procedure Access . Visibility from many mobile devices . Usage Analytics . Frequency of LOTO, by line, plant, shift . Downtime tracking . Reasons for lockout, areas for improvement

Lockout/Tagout Procedures Mark’s Goal: Digitize to simplify the process and increase productivity

. “Minor servicing activities…if they are routine, repetitive, and integral to the use of the equipment…performed using alternative measures which provide effective protection” . Minor Servicing Procedures . Only for specified tasks . Clear limitations . Risk assessments to prove safe and effective . Benefits . Increased Uptime . Cost Savings . NOTE: Risk assessments must be completed to prove the necessary level of safety is present, prior to utilizing minor servicing procedures

. LOTO procedures must be developed and documented for all machines . Are there gaps in your current program? . Do some procedures need to be re-reviewed for compliance?

. Procedures should be easy to use and accessible . How could you improve your procedure usability and accessibility for your team?

. A good LOTO program increases productivity by minimizing downtime . How else would you like to enhance your program to save on downtime?

PUBLIC

Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 28 Understanding Training Needs . “The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees.”

. “Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.”

. “Affected employees shall be instructed in the purpose and use”

Employee Training Juan’s Goal: Ensure employees have knowledge to safely work on machines

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 29 Developing Training Content . Authorized Employee Training . Know when lockout is needed . How to use written procedures . Recognizing and controlling hazardous energy . Affected Employee Training . Limitation to their job description . When lockout is needed and who to contact . Their role in LOTO

. Simple training videos . Supplemental classroom and hands on information

Employee Training Juan’s Plan: Video training, supplemented with company-specific information

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 30 Improving Training Program . Interactive classroom training . Core information . Video clips with discussion . Audience interaction, questions . Competency quiz . Ensure comprehension . Retraining, if necessary . Hand-on training portion . Training at the equipment . Q&A Opportunities

Employee Training Jane’s Goal: Increase effectiveness of training, focus on employee needs

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 31 Making Training More Effective . Focus on key ideas by group . Auditors: What machines need LOTO, how to develop procedures . Authorized: When to use LOTO, how to use procedures; techniques for control & verification . Affected: Recognizing when LOTO is needed, recognizing LOTO in-progress . Referencing the corporate policy . Documented processes . Resource for questions . Alternatives for minor servicing activities . Focused on when alternatives are acceptable . Reduced downtime, increased productivity

Employee Training Mark’s Goal: Provide employees with knowledge, options, and support

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 32 New Training Content . Contractor Training . Basic training on company program & procedure usage . Short, site-specific video . Visitor Awareness . General awareness training . Added to visitor training

Employee Training Filling gaps with additional training for others

. Training must be provided for authorized employees on how to perform LOTO . Are your employees trained on everything they need to know?

. Affected employees need to be trained on their role and limitations . Do your affected employees know what they can do and what can’t be done without LOTO?

. Consider others such as visitors or contractors, to ensure they are aware of the LOTO program

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. “Lockout devices and tagout devices shall be singularly identified; shall be the only devices(s) used for controlling energy; shall not be used for other purposes”

. “Shall be standardized within the facility in at least one of the following criteria: Color; shape; or size”

. “Shall be substantial enough to prevent removal without the use of excessive force”

Lockout Devices Juan’s Goal: Provide needed hardware for compliance

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 36 Standardizing Lockout Hardware 1. Standardized locks & devices 2. Inventory & threw out unnecessary devices . Damaged/broken devices . Non-standard devices 3. Determined which devices were needed . Employee input . Right devices for valves/disconnects 4. Ordered sufficient quantity . Assigned locks for maintenance; lock stations for other employees . Enough to lock out multiple machines . Group lockout needs

Lockout Devices Jane’s Goal: Ensure enough device inventory for team usage

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 37 Strategic Device Inventory & Placement . Looked for easiest application . Tested multiple devices . Employee input . Installed device stations . Multiple stations throughout plant . Shorter walking distance to grab devices . Purchased additional devices . More devices located closer to operator stations . ROI on increased inventory

Lockout Devices Mark’s Goal: Make locks & devices more accessible, saving time

. Locks and devices must be standardized by color, shape or size . Do you have a standardization in your facility? . Does everyone know which locks are for LOTO?

. The more accessible locks and devices are, the quicker it is to perform LOTO, increasing uptime . How could you make locks/tags more accessible?

. Consider if you have the correct locks and devices for your equipment

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Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 40 Requirements for Annual Inspection . “The employer shall conduct a periodic inspection of the energy control procedure at least annually”

. “The periodic inspection shall include a review, between the inspector and each authorized employee, of that employee's responsibilities”

. “Retraining shall also be conducted whenever…inadequacies in the employee's knowledge or use of the energy control procedures”

Annual Lockout/Tagout Audit Juan’s Goal: Maintain program and meet compliance requirements

. LOTO Procedure Review . All procedures . Accuracy, machine modifications . Authorized Employee Audit . Sampling of employees . Program being utilized, employees are knowledgeable . Inspection Form . Machine/employee being inspected . Date of inspection . Auditor name . Inadequacies identified

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 42 Using Audit to Review Effectiveness . Method for completing audit . Divided responsibility by department . Weekly targets to complete audit . Follow up tasks documented & scheduled . Developing new procedures . Updating procedures to reflect machine modification . Retraining, as applicable . Digital records of audit . Evaluating the effectiveness of the program . Overall safety culture review . Employee feedback for additional improvements

Annual Lockout/Tagout Audit Jane’s Goals: Ensure program is kept up to date

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 43 Leveraging Technology to Complete Audit . Tablet-based program management system . Tracking procedure audit status . Completed, coming due . Ability to assign audits to individuals . Employee audit . Customizable questions to gauge competency . Action item list . Automatically generated . Procedure updates, retraining

Annual Lockout/Tagout Audit Mark’s Goal: Digitized system to track and complete annual LOTO inspection

PUBLIC Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. 44 Benefits of Digital System . Reduces annual admin burden . Automatic record keeping for compliance . Gives better and consistent audit data . Corporate oversight . Allows group collaboration

Annual Lockout/Tagout Audit Usable analytics to improve LOTO program and increase plant productivity

. LOTO procedures must be audited annually . Are you keeping up with your audits? . Do you have the needed plan and resources in place to inspect all procedures

. Authorized employees must be audited for knowledge and compliance . Retrain as needed on the program

. Overall, what are your challenges to maintaining your LOTO program? . What tools or resources do you need to ensure you’re maintaining your investment?

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Program Strengths & Gaps Other Considerations  LOTO Procedures  Needs of the end user  Employee Trainings  Who’s responsible for upkeep?  Policy & Escalation Point  Plant environment  Devices & Hardware  Your current safety culture  Annual Audit  Program upkeep

How much time can you commit to your LOTO project?

Who is your team and their time commitment?

How advanced of a program can you develop?

Other projects and program “wants”

Do you need outside support to complete the program?

Policy People Program

• Update corporate • Ensure team • Order needed policy with changes alignment hardware • Incorporate roles & • Update training • Incorporate into project ownership material to reflect management, other • Document new changes policies processes • Retraining • Check in with changes

Simplification is key. A program must be simple to implement, simple to use, and simple to maintain To achieve program adoption, you must consider your people you must have team buy-in.

It is not enough to be safe, you must also be productive

RA Safety Page RA/ESC LOTO

Other Related Sessions T02 Introduction to Safety Standards T03 Risk Assessment Methodology T07 Workplace Safety Working Together; OSHA/NFPA and Employees