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Answered by Stephanie Lefever, product marketing specialist, Brady, Milwaukee.
Companies think lockout compliance is as simple as purchasing padlocks, tags and lockout devices. But when you look at OSHA's standards, lockout/tagout compliance is actually much more than just devices. In fact, the top five OSHA-cited sections of the lockout/tagout standard have nothing to do with protective materials and hardware.
The top five sections cited by OSHA are:
- Failure to develop, document and utilize procedures
- Failure to establish and implement a written program
- Failure to conduct a periodic inspection of the energy control procedure
- Failure to provide training as described by OSHA
- Failure to clearly outline the scope and rules to be utilized, and the means to enforce compliance
To ensure your company's lockout/tagout program is compliant, review your current program using this four-step process.
Step 1: Develop and document your energy control program and written procedures. According to 29 CFR 1910.147 (c)(1), you need to "establish an energy control policy/program consisting of energy control procedures, employee training and periodic inspections." A written lockout policy should always be your starting point – the foundation of an overall program. First provide a documented overview of your program, and then move on to develop machine-specific procedures, training and periodic inspections.
Step 2: Identify and mark all energy control points. To meet either OSHA or ANSI standards, you need to locate and mark all of your facility's energy control points – valves, switches, breakers and plugs – with permanently placed labels or tags. Cross-reference each label and tag with the corresponding step number in the energy control procedure, and be sure to include information about the control point's magnitude and purpose.
Step 3: Train employees and conduct periodic inspections. OSHA requires you to train your employees on lockout/tagout and provide proof of this training. Comply by establishing formal training programs for OSHA's three employee categories: "Authorized," "Affected" and "Other." One of the easiest ways to accomplish this is through a lockout professional software program.
OSHA also requires "a periodic inspection of the energy control procedure – at least annually." A third party or qualified employee (must be a different person than the one who originally wrote the procedures) must conduct an audit to ensure inspections are effective.
Step 4: Equip employees with proper lockout tools and warning devices. A successful lockout program depends on your employees properly applying lockout hardware according to established procedures. It is vital to know which specific devices are acceptable to use at each lockout point. If you are unsure which devices you need, contact a lockout device provider. A lockout device provider can offer a detailed list of required products specific to a facility and personnel.