The Role of Alternative Procedures in a Successful Lockout Program

Before any alternative methodology is selected, a hazard assessment should be performed for each task.

• By Todd Grover
• Mar 01, 2016

Frequently, maintenance personnel and machine operators are challenged to fully isolate and lockout machinery when power is determined necessary to complete the task. Other challenges arise when some power is needed to maintain a safe working condition or when disruption of key energy sources is infeasible for legitimate reasons. These challenges can frustrate well-intentioned workers if they perceive the safety requirements keep them from efficiently performing their work.

Because worker safety cannot be jeopardized, measures must be taken to strengthen process, educate on the need, and engage the operators in effective solutions. This article will address alternative procedures as a key, and often misunderstood, element of a successful safety program.

There are situations where lockout may not best fit a specific set of tasks—when equipment function such as settings, data, temperature, and motion are needed for alignment or testing purposes or when troubleshooting electrical circuits or pressurized systems under a variety of production circumstances permits visualization of the problem at close proximity. To identify where potential safety risks could occur, check simple tasks in hazardous locations, quick tasks where it takes longer to lock out than perform the task, and tasks that need to frequently restore function for testing or positioning purposes.

OSHA's Hazardous Energy Control regulation (29 CFR 1910.147) is a specification-based standard that clearly states facilities are responsible for establishing a written program covering how required safety measures will be applied. This includes provisions for developing machine-specific energy control procedures, training authorized workers to protect themselves with lockout/tagout, and for periodic inspections of the adequacy of the written procedures, as well as the performance of personnel applying them.

The requirements of the lockout/tagout standard are designed to safeguard employees from the unexpected energization or start-up of machinery and equipment, as well as the release of stored energy during service, repair, or maintenance activities. (See 29 CFR1910.147 (b) for a complete list.) OSHA does not routinely consider interlocked guards or emergency stops alone to be effective protection. Most of them only affect control circuitry and not the actual energy sources that could cause harm. A failure or malfunction of these types of devices, intentional or otherwise, could lead to disaster. In the midst of these energy control requirements, OSHA makes an exception for cord-connected equipment as long as the plug is closely controlled by the one worker doing the servicing. OSHA makes another exception for simple, single-energy source machinery, which does not require written procedures but must still be locked out during maintenance or repairs.

But the exception most often misunderstood or abused in workplaces is the one granted by OSHA for routine and repetitive production-related tasks as long as equivalent protection is provided for workers exposed to related hazards. The regulators are explicitly narrow in their definition of what is allowed under this exception. The potential trouble occurs when employers and their workers do not adequately document what the potential risks of the work are and what control (alternative) measures, in place of lockout, will be used to protect workers when energy must be present to complete their assignments.

To be clear, if isolation and lockout of all energy sources is feasible before performing a task, that should be the method selected to protect the people doing the work. Extra time or convenience is not an acceptable excuse why lockout was not performed. Alternative measures used in recurring production tasks depend on effective measures taken to isolate the particular energy sources that could affect the location where the work is performed. These measures can include partial lockout procedures to adequately lock out a section of a piece of equipment, rather than the entire machine. These measures also can involve special precautions—such as temporary barriers placed over hazardous exposures, special tools, and reaching mechanisms—rather than hand or body contact, as well as blocking or restraining devices that would reliably stop any unexpected machine action that could impact workers.

Following the Hierarchy of Controls
When developing alternative measures, a hierarchy of controls should be used to determine the highest and best solution possible to achieve consistently successful completion of the task. Eliminating the hazard by design is the highest level of protection. Safety-rated machinery often contains fail-safe interlock protection, as well as redundant control circuitry, that opens energy isolation points rather than simply interrupting operational signaling. Good detail is provided in the current ANSI Z244.1 Standard, with an expanded section in the new version of this standard due for release in 2016.

Opportunities exist with maintenance procedures to document application of controls measures within a work instruction to specify the way a task is to be safely conducted. This can justify the necessary presence of energy for testing and positioning of equipment so long as personnel are qualified to perform the work and are periodically confirmed to be working in accordance to the work instruction. Examples here may include safe working distances, electrically protective PPE and instruments, and pre-task evaluation of worker competency.

Before any alternative methodology is selected, a hazard assessment should be performed for each task. This should include a risk assessment that evaluates the likelihood of an accident occurring and the severity of the expected outcome. Documenting alternative procedures with a Job Safety Analysis (JSA)-type method is essential for communication, training, and recordkeeping. Performing this type of assessment before control measures are selected, and then again for each control solution considered, will quickly identify which safety measures are feasible to use. The best control options will dependably protect the worker with no chance for unexpected start-up or release of energy. If the alternative measure does not provide enough improvement for the investment, lockout is always there as the effective solution.

Most often, the task hazard evaluation process identifies very positive controls that can effectively protect personnel and reduce the time required for servicing or repairs. This results in increased efficiency without compromising the safety of the operation. The cost savings can be applied to other safety-sensitive operations requiring a similar investment to protect personnel.

Task Hazard Recommendations to Consider
When determining task hazards, use a task-specific analytical method that includes identified control measures to be applied. This step-by-step process will ensure that machine hazards are properly identified, associated risks are evaluated, and appropriate measures are taken to reduce those risks to an acceptable level.

Most importantly, be honest and conservative in your assessment. Simply put, if someone could be injured despite the alternative control measures under consideration, it is clear that other measures must be employed or the task requires full lockout.

A Task Hazard summary assessment focuses on tasks associated with the intended use—and reasonably foreseeable misuse—of machines, equipment, and processes. Some categories that should be taken into account include machine/process set-up, all modes of operations, teaching and programming, tryout and start-up, and more.

One method is to list all qualifying tasks and identify who performs each specific task and all potential hazards associated with the release of energy or unexpected start-up. You can evaluate the frequency of the task and the severity of the outcome using the HIRAC (Hazardous Identification Risk Assessment & Controls) matrix. First, assess the task as if no protective measures were to be used. Apply severity and frequency accordingly. Then, specify the control measures required for each task before re-rating the task using the matrix with the specific protective measures in place. Any score of "3" or more needs reassessment and additional controls. Use the results of your assessment to train personnel and verify safety requirements are being followed.

All movement and energy-related hazards—such as mechanical, electrical, thermal, pneumatic, hydraulic, radiation, residual or stored energy, motion, fuels, and human factors associated with each task—should be considered. This includes all servicing and maintenance activities and production-related tasks such as: operating, adjusting, cleaning, troubleshooting, and programming.

Taking these thoughtful precautions when lockout is a challenge to apply can drastically reduce the chance for an unexpected start-up or energy release to turn a good day into a bad one.

This article originally appeared in the March 2016 issue of Occupational Health & Safety.