Jimi Michalscheck – business development manager at Rockwell Automation – opened the EHS Today’s Safety Leadership Conference with the following line: Safety doesn’t have to come at the expense of productivity. This was a sentiment that was welcomed rather warmly by the crowds of EHS professionals in attendance as this is what they have been pushing in their own plants for years.
There is often wiggle room in many safety systems and regulations which leaves enough flexibility for engineers to work alongside the EHS team to maximize safety and not interrupt work processes. Michalscheck continued, “Following OSHA’s lockout/tagout definition, there are certain parameters that you absolutely have to follow. There’s no wiggle room.” Lockout/tagout procedures are put in place to ensure that everyone is safe no matter what bypass operators try to sneak in. While safety is absolutely necessary the machines being shut off can add up to some costly downtime.
To continue his point, referring to case packers Michalscheck said, are “notorious for jamming, notorious for interlocks, and notorious for accidents and citations because of the frequency people are in them.” He estimated that a full LOTO on one of these can take up to 15 minutes to complete and that the machine can jam five times in an hour of operation. This could potentially add up to $23,000 in lost productivity per hour, per machine, he said.
“But what if I told you,” he added, “that we could design a different system that only takes 30 seconds?” He was referring to an exception tacked on to OSHA’s LOTO requirements (1910.147(a)).
Michalscheck concluded, that if engineers and EHS teams work together to create standard safety systems and equipment on their machines to handle these kinds of service operations that provide the same measure of safety as full lockouts, then they can go without LOTO. If deployed appropriately, APMs can provide operators the same safety and security as LOTO, but without the costly downtime.
“You don’t have to shackle your productivity for safety,” he said. “As long as you can design something that is as effective as lockout/tagout, you can do it. In fact, engineering safe alternatives is key to establishing advanced lockout/tagout.” If a machine jams in one particular area or one particular function, there is not necessarily a need to power down and lock out the entire machine to free it. Crews can design an alternative safety system that protects workers in an isolated area of the machine. This will allow them – protected by guards and triggered e-stops, for example – to free the blockage, correct errors and restart the machine with minimal downtime. These alternative measures can be powerful productivity tools on the plant floor. However, they do still require quite a bit of diligence and collaboration to design.
“If you want to do anything other than lockout, I recommend that you treat it just like lockout,” he advised. “Just because OSHA doesn’t require you to document, doesn’t mean you don’t have to do it.” You will need to design the procedures, document, audit, train and incorporate them into policy and hold yourself to the same bar of safety that OSHA regulations demand. Developed properly, these systems can provide much needed flexibility on the regulations. An increased risk to employees by using alternative protective measure procedures is not acceptable. Any APM developed must should always provide an equal or greater level of protection as LOTO does.
“APMs aren’t just an advantage to ROI and competitive edge,” he added. “These are really, really big penalties at stake.” And, it’s worth noting, people’s lives and limbs as well.”