Just before the Covid Pandemic hit us all hard I was talking to a potential new customer. He was a Safety Manager at a large machining operation, and we were in his office. We were discussing if I should or could assist them with his safety program. I asked him several questions and allowed him to ask questions to me as it is important that the customer understand what I can do and why. We had a very informative conversation, things were looking good, and I was thinking to myself, “From his words they seem to get the idea of safety culture so this might be a good relationship.”
It was at this moment I asked my host, “Do your employees practice good lockout practices?”
My host replied, “Oh yes all our employees lock our whenever they should!”
I immediately asked, “How do you know?”
To which he replied, “We have had no major accidents and they seem to be practicing lockout when I look,”
I thought to myself, “Well now, that was not the exact response I was looking for so it looks like we will have some work to do! The response should have been, ‘Our lockout audit program reflects that we are practicing lockout as we should, and our program is effective!’” I would soon find out I had more of a challenge than just that!
Soon thereafter we agreed to go on tour of the plant. We put on the necessary PPE and left the office area for the plant. Not 10’ inside the Plant Entrance I looked across the isle to see a major overhaul taking place on a large but old CNC Machining Center. I observed three maintenance technicians inside the machining center removing a cutting head. I could see no lockouts on the machine and the operating lights were on the main control panel. The machine was obviously energized. I turned to my host and immediately asked, “Where are the locks?” Are these people safe?”
My host tried to explain something about losing the program in the old control unit. About that time a Maintenance Supervisor saw us and approached us. He looked at me and asked, “Who are you and why are you here?”
The Safety Manager said, “He is a Safety Consultant here to help us.”
I introduced myself to the Maintenance Supervisor and gave him my business card. I asked him. “Are these your men and if so, why is this machine not locked out?”
He replied, “Yes these are my men and they do not have to lock out the power!”
I said, “How can you justify that? The machine must be locked out at the main power disconnect to do a job like this! Do you have a Hazardous Work Permit Program?”
To which he replied, “We are calling this normal production operations. We cannot shut off the power or we will lose the programing in the main controller in these old machines! What is a Hazardous Work Permit Program?”
I looked at the Safety Manager and said, “At this point I realize I am only a guest. But you maybe soon paying me for my opinion. I am telling you this is NOT normal production operations, and it is extremely dangerous. I would highly recommend you get your people out of there! Next, can we go discuss this in a conference room off the floor as not to be a spectacle for your employees?”
The Safety Manager asked the Maintenance Supervisor to get the men out and stop the work. He next asked him to come to the Main Conference Room. On the way up to the Main Conference Room we some-how picked up the Plant Operations Manager. Once in the Conference Room the Safety Manager explained what had happened to the Operations Manager and introduced me. The Ops Manager calmly looked at me, “Why Tom, have you disrupted the Maintenance Schedule on an important machine that we need up and running ASAP!”
I looked at everyone and said, “You are the managers of this operation, is that correct?” Getting affirmative nods from all I then asked, “Did you all approve your maintenance employees getting in that machine? Further would you require your maintenance employees to go in a Permit Required Confined Space without an approved permit? We are talking the same logic here! Before you answer consider these things:
- Getting in your machine to perform an overhaul and remove cutting heads and chucks is not routine production operations. I am very familiar with CNCs their operation and OSHA’s 29 CFR 1910.147 The Control of Hazardous Energy and specifically 1910.147(a)(2)(ii)(B). I have too argued the later as an Operations Manager and a Safety & Health Manager, both ways. In this case a maintenance overhaul is no way production operations. Lockout applies per OSHA in this case!
- You have your men inside the machine. The men could possibly be electrocuted as there could be live electrical energy in the machine and if somehow the machine cycles could be killed when the machine closes on them.
- Now as to the problem here of losing the program. In early 2020 there must be a way to save the programing in the control unit. I know you download the actual machine program specs for each job can you not save the other info the same way? Has anyone checked?
- Next if you check and there is no way to practically save the programing and must send people inside without Locking Out consider this:
- No one has the right to just make that decision without taking further steps to protect the employees. The law says you must protect your employees (OSHA General Duty) and the Lockout Standard requires if you do not Lockout other steps must be taken to protect employees! What are those things you can do to do just that? It is the same logic as approving a permit to enter a Permit Required Confined Space or approving a Hot Work Permit.
- As a manager you must realize that sending an employee into danger like that is taking huge financial risk! If someone is killed or has a serious amputation you are looking at anywhere from a $500,000 to a $1,000,000 per injury. Who here can assume they can make that kind of risk decision for this company without taking precautions?
- If you think you must allow people to not lockout an operation that should be for a job you need a Hazardous Work Permit Program. You want to plan that the risks be reduced and as managers I think you want to approve the remaining risk! In my opinion, PRCS and Hot Work Permits are forms of a Hazardous Work Permit Program. You extend this program to the RARE times your people they do not think they need to lock out!
- I have seen to many people get seriously injured because they felt they could take a chance and not lockout. In my Lockout Programs we remove “choice”! My employees understand locking out is NOT A CHOICE! Unless they get written approval to not lock out they MUST Lock Out! There is NO choice!
I have lived all the above. I also know the OSHA Lockout Standard requires audits to ensure your program is effective. I do not think you are doing them. You need to start. If we work together you will. Now I realize I am just a guest and may have ruined my chance to work with you! Well, I guess that it up to you, but you will pay me for my judgment and my knowledge. I will always tell you what I think, as I did in this case. The choice is yours. If you have any questions please give me a call. I look forward to hearing and working with you!
It has been a year now and I have enjoyed my work with the above company. Working together we have reduced their OSHA Recordable rate by 80% and significantly lowered their Workers Comp Mod Rate! If you would like my help please contact us.
Tom Fitzgerald
Owner and Sr. Safety Advocate
Safety Fitz LLC
www.safetyfitz.com
920-901-8860
This is a really good tip particularly to those new
to the blogosphere. Short but very accurate info… Thank you for sharing this one.
A must read post!
Thank you! In Manufacturing and Industry the “Control of Hazardous Energy” or Lockout is one of more important tools to keep safe! it is also the LAW. Thanks! Tom Fitzgerald