In my 50 years of manufacturing experience, I have seen all too many employee amputations, severe arc flash burns, and other catastrophic injuries. To my memory, the root cause of all these accidents is attributable to a failure to lockout. Related to most of of these accidents was a tendency to just blame the employee for not following the company policy on lockout. However, when an honest and thorough investigation was conducted, the culture of the organization allowed a pervasive attitude to allow employees not to comply with the lockout policy. There are four identifiable reasons for a company’s lockout policy to fail.
- Companies Do Not Follow the Intent of 1910.147. I am of the opinion, that 1910.147 is one of the most effective and if applied correctly effective standards in 29 CFR 1910. At its essence it teaches that its purpose is to give employees the tools to protect themselves from the unexpected release of harmful energy. However, somehow that message is corrupted when given to employees by management. The employees perceive it as a chore or at the least a time-consuming task, it does not become linked to their welfare and safety. In addition, there are five components in 1910.147 that are all important to the process of lockout. They all must be applied in a company’s culture for the process to protect employees. Those components are, #1 Scope, Application, and Purpose, #2 Procedure, #3 Protective Materials and Hardware, #4 Periodic Inspection, & #5 Training and Re-Training. If management is to have an effective lockout policy, it must be seen as an important benefit and tool for employees to keep themselves safe!
- Genuine Management Commitment. Most companies will say that lockout is important, but do they really mean it? Do they demonstrate lockout is important? How many managers understand the basic tenants of 1910.147? In most organizations the only authority in lockout is the person that is charged with the safety role. Lockout is not that difficult to understand if it is widely practiced and followed. There is no better example than the issue of who is and who is not an Authorized User of Lockout in an organization. These are the people that are supposed to apply the lockout policy in their work and use locks! Many companies merely limit the number of Authorized Employees to an absolute minimum. As an old manufacturing manager and supervisor, I understand all the costs to take people off the job to train, but I find this practice backwards. However, on this one the successful cultures maximize the number of Authorized Employees. Related is the question if supervisors of Authorized Users are in fact Authorized Users themselves? To my way of thinking of course they are, as they must enforce lockout being practiced by their employees. If they are not trained in the procedure, how can they enforce it? Also, they may have to lockout themselves, in inspecting and managing their employees. Yet I often see no management employees listed as Authorized? Commitment means you understand the importance and the requirements.
- Employees Are Allowed to Think They Have a Choice Not to Lockout! In every case when I have investigated an amputation, I would interview the injured employee. Very often this employee was an experienced and trained employee even journeyman. When I asked if they knew they should have locked out they universally said something like, “Yes, but I thought it did not apply to me.” Or they might have said, “Yes, but I thought I could take a chance, after all I know the job better than anyone else!” After hearing something like this all too often I started to teach Authorized Employees that there is NO CHOICE but to always practice lockout! I would explain the company has no choice but to apply 1910.147 by having a compatible procedure on lockout and the employees did not have a choice but to follow company policy. There are occasional circumstances where maintenance and setup must be done with the power on. Examples are troubleshooting and testing. 1910.147 allows for this if other protections are implemented. This does not mean an employee can use this as an excuse or as permission to just proceed unprotected! I believe an effective way to allow employees discretion and recognize their experience is using Hazardous Work Permits. If an employee feels they do not need to lockout they complete a Hazardous Work Permit and get it approved. The permit outlines the additional protections the employee must take to keep themselves safe. I sell this process to employees be explaining that a serious accident will cost several thousand dollars. Very few people in an organization have the right to incur that kind of risk without permission from a superior. Bottom line employees cannot think they have a choice in following lockout! By completing a Hazardous Work Permit employees outline how they will protect themselves. This process also recognizes the training and experience of the employees which is always important to them.
- Companies Do Not Have Their Employees Engaged in the Lockout Process. I have already alluded to this one, but I want to stress it even more. In many organizations the only authority on Lockout seems to be the safety person. The successful organizations in lockout have numerous authorities. Management employees promote lockout and understand when it is being followed and when it is not. In my last organization I had a Lockout Team! Instead of only me being the only recognized authority on Lockout, we had at least twenty of four hundred employees trained thoroughly in lockout. All of them regularly taught Authorized Employee Training classes! They were also all recognized as the “GO-TOO Lockout Authorities” on the plant floor. When it came to maintaining lockout procedures on machines and approving new machines for production, they were in the forefront of the processes! It made my job much easier! Every supervisor on the floor on all shifts had a couple people to use as Lockout Authorities. We increased the number of Authorized Employees from about 20% of our workforce to over 50%. There were other factors, but I am positive the existence of an active Lockout Team significantly contributed to the prevention of untold amputations. Prior to the Lockout Team we averaged two amputations a year in our large machining and tube forming operation. In the last 5 years I was at the organization we had no amputations! I think there can be no better evidence to support employee engagement!
For lockout to be effective it must be seen as a valuable tool for employees to use to keep themselves SAFE. If lockout is merely seen as, “Just something the Safety Guy (or Gal) makes us do,” people will lose fingers and/or hands! Employees need to make it as much as part of their jobs as putting on their safety glasses.
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