Jimi Michalscheck - CEO

Transcription

1 Advanced Lockout-Tagout Programs VPPPA National Conference 2014 Speaker: Lockout-Tagout is what we do. TM Jimi Michalscheck - CEO

2 What is the true intent behind hazardous energy control (Lockout-Tagout)? To prevent injury or death due to unexpected restart or reenergization during service of equipment. The modern art of controlling hazardous energy.

3 What is Advanced LOTO Advanced LOTO Programs are ones designed to ensure employee safety (and minimum OSHA compliance) while finding the most effective way to maximize productivity. Advanced LOTO programs must: 1. Have a sustainability plan 2. Utilize modern hardware 3. Evolve over time

4 Today s objectives Quick Review Basics Discovering hidden efficiencies in your programs Optimizing safety Techniques to sustain program Utilization of modern technology with LOTO

5 The 5 minimum required components are Procedures Auditing Training Equipment Corporate Policy

6 And we all know why these rules exist Source: Jack Benton ehssafetynews.wordpress.com

7 Discovering ways to make your own program better

8 Efficiency with Lockout-Tagout Top tips to achieve the most: Utilize a graphical format. Ensure the devices are localized by usage. Encourage all employees to help.

9 Graphical picture based procedures are more likely to be utilized and improve confidence. Random audits (peer-to-peer and 3 rd party mixed) ensure high quality performance measurements. Finding the safest approach

10 Communication: Expert Tip: Avoid excessive LOTO Downtime Authorized employees often forget to notify affected employees prior to starting their work and upon completing their work. Very important step for safety and efficiency They need to know when they can start the process back up. Planning: Encourage employees to take a few extra seconds when planning for the lockout-tagout process. A few seconds of planning can shave minutes off the process and help identify any discrepancies. Testing: Always test the equipment (most important step) If the procedure is inaccurate, remove it and notify the safety manager to have it updated & tested immediately.

11 Sustainability Understand that LOTO is a Dynamic system with known change rate (Assume 15% or more annually) Have one designated owner Rely on outside experts for big updates, daily updates should be done by in house staff Audits People, Procedures, Policy, Product Include a LOTO topic in weekly/monthly meetings to hear and address user feedback.

12 Modernize Utilize the best tools Select the RIGHT locks/devices to ensure it s easy. Use pictures of device being utilized right at the station to reduce guess work. Keep devices updated. Utilize electronic formats whenever practical (ipad, smartphone, etc.). Mount procedures at point-of-use using durable formats.

13 Lockout Tagout Best Practice Usage of Graphical procedures & tags Mount your locks/devices near where they are needed Keep the devices stocked, updated and high performance (with usage pictures and training) Random audits throughout the year Electronic tablet auditing (ipad, etc.) Seek outside audits for objective feedback

14 Note for those with large programs Avoid proprietary programs that might lock you into annual fees or the use of their program exclusively to access, create or maintain your procedures. Just use MS Excel - it has all the capability and future expandability you need: Enterprise capability Editing on a tablet Custom programing Sharing, networking, updating real time Free with no annual fee

15 Top 10 Avoids Common pitfalls 1. Lack of Machine Specific Procedures (c)(4) 2. Not performing annual audits of procedures and employees (c)(6) 3. Lack of Training of all your employees (authorized, affected, other) (c)(7) 4. Wrong use of tags & locks (c)(5)(ii) 5. No corporate policy 6. Working under someone else s lock (d)

16 Top 10 continued 6. Not identifying all energy source or adjacent equipment (b) and (c)(4) 7. Not understanding when to administer lockout (major vs. minor maintenance) 8. No oversight or plan for continuous improvement/review 9. Duplicate keys existing just use bolt cutters to send the right message

17 Additional Information Most common issue with LOTO Companies don t identify the correct equipment requiring a procedure.

18 All 8 Criteria Must Be Met! CFR (c 1. Have no potential for stored or residual energy 2. Have 1 energy disconnect which can be easily isolated 3. Be completely isolated and deactivated by that one disconnect 4. Be able to be locked out during service or maintenance 5. Be able to be locked out using only 1 device 6. Have the device under exclusive control of the employee for the duration of servicing 7. Be able to be serviced without creating hazards for other employees 8. Have no prior accidents due to uncontrolled energy

19 Does this need a procedure? Natural Gas Boiler

20 What About This Machine? Air Handler Unit

21 What About This Machine? Rooftop Exhaust Fan

22 What About This Machine? MIG Welder

23 What About This Machine? Grinder 120V

24 Electric Fork Truck What About This Machine?

25 Note: All the aforementioned equipment requires a machine specific lockout-tagout procedure per the 8-criteria set forth in (c)(4)(i) Further information/tips (time permitting and for offline review)

26 Ensure the procedures stay accurate and you can prove you audited it. Procedures must be audited at least every 12 months (as well as authorized employees).

27 Maintaining your LOTO Program Employees must be audited annually on their use of LOTO procedures to ensure proper utilization and understanding. Perfect time to identify any deficiencies in LOTO procedures or overall expectations of authorized employees. *sample audit form available on *available for download on

28

29 PROCEDURE INSTALLATION TIPS When procedures are installed at the point of use, authorized employees are more likely to utilize the data, they spend less time locating the correct procedure, and the mounted procedure will serve as a great tool for emergency responders in the event of an emergency.

30 PROCEDURE AND TAG MATERIAL Use properly engineered materials Tip: Utilized injection molded procedures for outdoor use to yield 10+ years UV and over 150 lbs. pull force. Use of injection molded energy isolation tags to speed the process up

31 Authorized Employee Must be provided to each authorized employee prior to legally using lockout-tagout. HOT TIP: Offer different options Hour, 3.5 Hour, & 8 Hour Sessions depending on the skill levels and usage of LOTO. Affected Employee Awareness Training Generally a 1 Hour Session Annual refresher trainings are recommended

32 Review all procedures to ensure quality and safety. Fix any discrepancies immediately Utilize tablets to make real-time corrections for easy fixes Be prepared to install missing isolation point tags

33 A good corporate policy should be clear and easy to understand. Review and update the policy annually to ensure performance. If no policy exists (or policy was lost), immediately contact ESC to receive a free policy template to start customizing today.

34 Utilizes QR codes at point of use Audit LOTO program real time 50% more efficient audits Keeps electronic records of procedure and employee audits via dashboard

35 ScanESC - Fully electronic lockout-tagout program TOP BENEFITS Identify trends you never knew before with auto-generated usage logs. Don t deal with the hassles of printing documents keep it all electronic and in the cloud. Proactively manage your audit dates with proper resource planning. Important Reminder - Make sure the solution is NON-proprietary you should always OWN your data and be able to move it to another future platform if desired.

36 End Of Presentation Join the discussion- over 3,000 fans, just like you

37

38 Fine info as of OSHA.gov fine stats broke down by category

39 FY $12,072,266 total New Mexico New York Minnesota New Jersey Nevada Oregon North Carolina OSHA Fines FY2013 South Carolina Tennessee Virginia Washington Utah Vermont Wyoming Maryland Kentucky Indiana Iowa hawaii connecticut Michigan california federal arizona alaska

40 Fines and Citations by State OSHA Programs LOTO - STATE FINES $3 600 $2 500 FINE AMOUNT (IN MILLIONS) $2 $ $1 100 $0 AK AZ CA CT HI IN IA KY MD MI MN NV NJ NM NY NC OR SC TN UT VA VT WA WY Penalty $0.029 $0.012 $2.078 $0.001 $0.005 $0.340 $0.116 $0.152 $0.022 $0.792 $0.148 $0.060 $0.000 $0.011 $0.000 $0.259 $0.043 $0.033 $0.121 $0.064 $0.050 $0.003 $0.124 $0.028 Citations Inspections

41 Questions / Topic Requests from VPPPA National 2014 Are there any recent changes to regulations? Looking for clarification on minor servicing of machinery and usage of SOP (Standard Operating Procedures) Looking for techniques to verify a breaker is at Zero Energy State Techniques for reinforcing policy compliance Defining exclusive control Procedure inspection requirements Machine specific procedure requirements (8 criteria) Risk assessment process requirement and details New Technology for LOTO Suggested enhancements for existing programs that are used for construction then not used any longer for production

42 Questions/Topics from the audience VPPPA Attendee: Are there any recent changes to regulations? ESC Response: Yes, in fact there was a final ruling by OSHA that just went into law on July 1 st. There was an extension put in place, but it will significantly affect the power generation industry and their new lockouttagout requirements. More info on these pages:

43 Questions/Topics from the audience VPPPA Attendee: Looking for clarification on minor servicing of machinery and usage of SOP (Standard Operating Procedures) ESC Response: Whenever your company elects to circumvent the need for lockout-tagout when performing service work, be sure it meets the requirement as a routine, repetitive and integral to the process (no major work without LOTO). Then follow careful steps to ensure a procedure is developed and followed that provides at least an equivalent level of protection for that particular service work. Resource:

44 Questions/Topics from the audience VPPPA Attendee: Looking for techniques to verify a breaker is at Zero Energy State ESC Response: If work is being done in a panel, remove power up stream from panel and follow NFPA 70E protocol for testing to ensure deenergized prior to servicing. For work on machines that involves isolation of a breaker to remove the electricity, you can add a verification step that will help ensure the process worked typically Attempt to restart machine will suffice, but other times if there is no control panel, then a multimeter will need to be used. Make sure your electrical safe work training is up to date if employees are going to be using DMM equipment.

45 Questions/Topics from the audience VPPPA Attendee: Techniques for reinforcing policy compliance ESC Response: Some of the best techniques involve random audits/inspections and peer-to-peer reporting. This will ensure your program is adopted 24/7/365 not just in December when everyone knows you re walking around checking for compliance. If root cause for policy infractions are because they didn t know use periodic trainings and signage to help remind.

46 Questions/Topics from the audience VPPPA Attendee: Defining exclusive control ESC Response: When someone is working on a piece of equipment and they choose to not lock it out, they must maintain exclusive control of the equipment to avoid the lockout. This can only be utilized on cord and plug equipment. We recommend not using this technique unless it s critical to daily operations. Many times, it leads to confusion as to why sometimes employees don t use locks, and other times, they do.

47 Questions/Topics from the audience VPPPA Attendee: Procedure inspection requirements ESC Response: Each procedure is required to be inspected for accuracy at least annually. Grouping equipment under one procedure can be useful for portable equipment like fork trucks and welders, but should not be used for fixed facility equipment. Anyone your company desires to inspect your program is permitted to do so In fact, industry best practice is to use personnel who are less familiar with the equipment to audit. This ensures a less biased and more detailed review of all aspects of the system.

48 Questions/Topics from the audience VPPPA Attendee: Machine specific procedure requirements (8 criteria) ESC Response: Covered in training slides above. This is the most commonly overlooked aspect of US Companies lockout-tagout programs. To avoid this pitfall assume ~95% of your equipment will need a procedure. Perform a full site assessment and document rational for any machine that you feel meets all 8 criteria. Check your OSHA 300 log annually to ensure those pieces of equipment were not involved in an accident that related to LOTO.

49 Questions/Topics from the audience VPPPA Attendee: Risk assessment process requirement and details ESC Response: Risk assessments are not required per , but they are required by the PPE standards Here s what OSHA says: "The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE)." "The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the dates(s) of the hazard assessment; and which identifies the document as a certification of hazard assessment."

50 Questions/Topics from the audience VPPPA Attendee: New Technology for LOTO ESC Response: Tablets are the easiest and least expensive technology that will transform your lockout-tagout program. They have become less expensive, more accepted in business. With the right cases, tablets are waterproof, drop proof, dust proof and even certified as Class1Div2 devices. With tablets, you can access, update, interact, inspect and utilize your lockout-tagout program real time. Tablets allow you to gain efficiencies that you never could before.

51 Questions/Topics from the audience VPPPA Attendee: Suggested enhancements for existing programs that are used for construction then not used any longer for production ESC Response: The OSHA regulation for construction is 1926 and it was recently updated with the final ruling stating that lockout-tagout is required with any construction project in any industry. Recommendation for improving existing construction program: Create a clear decision tree that can be used to create consistent procedures as needed and before work takes place. For any equipment you know will need a procedure prior to work, create the procedures and display them on the machine during installation. Keep the group lock box near the procedure so contractors can easily verify the information as they come and go from the lockout-tagout process.

52 Additional Questions/Topics from past audiences

53 Questions/Topics from the audience VPPPA Attendee: Looking for new ideas for procedures. ESC Response: Try using graphical pictures to help enhance your existing procedures. Use the pictures as a road map to more quickly explain where the isolation points are for the equipment. If you already have pictures, work towards a solution that helps eliminate waste such as utilization of tablets to view/edit/access the procedures.

54 Questions/Topics from the audience VPPPA Attendee: What are good solutions for record keeping and tracking audits? ESC Response: Depending on your size, there are different approaches. If you have 100 procedures, using a simple MS Excel spreadsheet and hosting it on your server might be the best solution (and free). If you have several hundred or several thousand, you will need a robust enterprise level solution like ScanESC that brings all your data together and help make your program much more manageable.

55 Questions/Topics from the audience VPPPA Attendee: What is good lockout-tagout software to use? ESC Response: Any software that allows you to manage your program more effectively without trapping you into a proprietary foundation. There are several out there that are very proprietary and if you discontinue the use of the software, you will likely loose your entire investment. ESC recommends MS Excel as a foundation for all procedures for stability, future proofing the program, and familiarity. ScanESC is a solution by ESC that leverages your MS Excel procedures to their fullest without using proprietary software that prohibits future options.

56 Questions/Topics from the audience VPPPA Attendee: What are good tools to use for lockouttagout that are new or highly rated? ESC Response: Solutions vary depending on desired objectives. If a company wants inexpensive and universal tools, then lightweight self retracting cable devices work great for this. Master Lock, Brady, Panduit, and Zing all make very high performance devices that are geared for different needs. One new device we like is a breaker device by Panduit that just hit the market. Our tests have shown their product to hold the tightest with the least wear on the breaker. Search Panduit breaker device to learn more.

57 Questions/Topics from the audience VPPPA Attendee: For the refining industry - what are some common pitt-falls or challenges we should look out for? ESC Response: Refining is a unique industry in that the process and product itself can pose additional safety hazards beyond the lockable energy sources. Chemical, Thermal, and Potential Energy in the form of gravity all pose grave dangers if they are not properly controlled. The most common pitfall with LOTO systems in refining is the lack of approved processes for commodity-style equipment. Example: If heat exchangers have the same LOTO approach utilized as the piping system procedures, then there may be potential safety and compliance issues. To remedy, follow the 8 criteria to pre-write procedures for fixed equipment and review the process utilized to create system procedures annually to ensure safety and compliance.

58 Questions/Topics from the audience VPPPA Attendee: Advanced electric motor verification steps ESC Response: When locking out electric motors to service, it s important to also lock out adjacent systems if they pose a hazard while servicing. For instance, in a mine if you were to service an electric motor on a large conveyor, it would be important to take steps to ensure the infeed and exit conveyors do not operate if they pose a hazard while servicing. Common issues associated with High Voltage verification is that many contact meters are not rated high enough to verify after testing. Taking steps with no-contact meters that measure the electric differential within the electromagnetic waves that emit from a live circuit would be a great first step. Also, verifying at the control panel by attempting to restart. Note: If you are about to service high voltage electrical disconnects, you must also follow NFPA 70e rules and practices that will protect you in the event of an arc flash until the circuit is known to be at zero energy state.

59 Questions/Topics from the audience VPPPA Attendee: Mechanical lockout with devices vs. using tag out when and how should you choose with is best when practicality is a concern (i.e. carrying 70 very heavy chains to lock out valves). ESC Response: The ideal lockout-tagout solution varies depending on the industry. For a high value, but low volume industry, it might be practical to use the chains. For a high volume, high value industry (like power generation and others), it might make sense to use a lightweight cable device to secure the valves. Tagout is no as secure as lockout+tagout together. Tagout is only permitted when there are additional steps taken to ensure an equivalent level of protection is established. That is a difficult concept to prove in the event of an accident. Industry best practice Find the best device and lock solution to meet the intended application. Work with 3 rd party experts to get a plan in place and test it before implementing system-wide.

60 Questions/Topics from the audience VPPPA Attendee: What are some common exceptions or alternatives to LOTO Such as when performing minor or routine maintenance. ESC Response: Lockout-Tagout is needed when you absolutely need no chance for unexpected startup. If you are performing diagnostic work, calibration work, programming tasks, or other tasks that are only possible when the equipment is partially energized, then protecting the employee with solutions such as SOP (Standard Operating Procedures) is one very high performance solution. A standard operating procedure must provide the equivalent level of protection as the lockout for the intended task. These are not referenced by OSHA, but are a critical tool to find hidden efficiencies in any safety program.

61 Questions/Topics from the audience VPPPA Attendee: Tips for standardization. ESC Response: To have an OSHA compliant program as well as one that is effective, it s important to keep all your procedures, policies, locks/tags/devices, and general duty expectations for each safety manager as consistent as possible to ensure the integrity of the overall solution remains in tact. One tip for this is to use a central server for accessing a common template that can be used to create the procedures. This will ensure all sites are using the same tools. For devices, it s helpful to keep an inventory of what devices are preferred and why so that future upgrades can be made with prior historical knowledge. Lastly, for training, having all training files downloaded from a central server will help keep fresh information consistently delivered system wide.

62 Questions/Topics from the audience VPPPA Attendee: When is it okay to use a lockbox and when is it okay to find an alternative? ESC Response: OSHA doesn t require lock boxes be used, rather that is quite often a corporate policy that will be written specifically that way for industry specific reasons and preferences. Example: Assuming no conflict with your corporate policy, if only two people are working on a piece of equipment and only two lockout points are involved, a lock box might not be the highest performance solution. Instead, opt for a hasp for ease of use and reduced components to manage. Note: Lock boxes are great for situations when many people will be added to and removed from a lockout process. Simply applying one lock to the lock box provides the equivalent level of protection as applying a lock to each energy source saving time and reducing the wear and tear on the isolation points.

63 Questions/Topics from the audience VPPPA Attendee: Train the trainer requirements what are the minimum requirements? ESC Response: OSHA does not list minimum requirements for knowledge, credentials, or certification a trainer must have, but instead does list the required objectives from each training. After a training is provided, all authorized employees (those applying the locks) must fully understand their roles and how to properly utilize lockout-tagout in their job to be safe. To effectively meet the training requirements, the designated trainer should test all attendees of the training, retain the tests (with names and dates), and require retesting if the tests show lack of full comprehension. Additionally, allowing for hands on training and feedback will ensure further proof that the employees understood the training and know how to utilize daily. Annual refresher trainings are not required, but highly recommended as industry best practice.

64 Questions/Topics from the audience VPPPA Attendee: Shift changes over holiday periods where certain personnel will lock it out and not return, but others must service and restart. ESC Response: When a lock is used for LOTO, it must be applied by the person who will be protected and removed by the same person. If a piece of equipment is desired to be rendered inoperable during a transition period (i.e. shift changes, seasonal outages, prepared for demolition), then an alternative solution utilizing separate locks and tags that are not designated or marked as lockout tagout specific may be used to prevent damage to the equipment. Having keyed alike locks in this situation might be very beneficial for convenience. Since locks are not required to protect equipment from equipment damage, you could also simply use a tag and zip tie if that helps achieve the objective better. Note: ensure you do not use any tags or locks that reference lockout-tagout or you could risk an OSHA violation. No matter the solution and approach a company takes, The overall integrity of the system should be maintained. That someone s life is being protected by this lock.

65 Need more information? Most safety managers we talk to agree that the concept behind hazardous energy control (Lockout-Tagout) is not that complicated. However, finding the correct solutions that meet each industry s and each company s exact objectives is not an easy task. If you have further questions, please feel free to reach out to ESC via our contact page and we ll be happy to assist. Lockout-Tagout is What We Do.