How to Safely Avoid Lockout
Safely avoiding lockout/tagout requires employees to be trained in proper safety practices. Employers are responsible for identifying tasks that can be safely accomplished by different means and making sure their employees follow rules and procedures. When procedures are properly implemented and followed, employees can safely perform their tasks, knowing the lockout-tagout requirements are OSHA approved.
1. Identify Tasks
The first step is for employers to identify tasks that are routine, repetitive, and integral to normal production that can be done safely. These tasks should be documented in the lockout/tagout policy as being exempt from lockout/tagout. Tasks can include minor tool changes, cleaning of the exterior of a machine, or minor adjustments that can be accomplished through the use of a tool or other means.
2. Train Employees
Next, employers should train employees how to conduct these tasks safely. Employees should always shut off the machine or section of the machine being worked on before starting work.
Proper PPE should be worn for the given situation such as gloves, safety glasses, or face shields. Tools may also be employed to reach into areas unsafe for employees.
Employees need to confirm they are in sole control of the equipment for the duration of work; for small units, this is done by shutting down equipment and being aware of others in the area, but it can also be done by removing control keys and/or blocking machine components. Finally, employees must always be careful in these situations and understand when a minor task becomes a major one, requiring lockout.
For tasks that are more complex, a Standard Operating Procedure (SOP) should be created and made available to the employees.
A good SOP should be specific to a given machine and list the limited number of tasks for which it applies. Specific steps should be listed for the employee to follow, which may include partial lockout of the equipment.
PPE and tools to be utilized should be included in the document. Alternate safety measures should be listed as well.
These SOPs must be documented and should be reviewed annually. They should provide safety and also be practical and efficient. SOPs are most often utilized for common jobs where locking out the equipment takes too long or proves to be impractical.
There are many instances where an SOP may be useful or where lockout may not need apply. Here are a few examples and their limitations:
- A bottle falls off a conveyor inside a packaging machine. If the bottle can be safely picked up by shutting down the machine momentarily, ideally with the use of some grabbing device, the machine would not need to be locked out. However, if the bottle is not easily reachable or if it is caught in the equipment, lockout would apply.
- A box or other object gets caught in a conveyor. If an employee can turn off the conveyor and pull the item free without getting their hand near the jam point or other hazards of the equipment, it may be acceptable. If however, the jam is severe and requires disassembly of the machine, it must be locked out.
- Small bits of debris get caught in a press head. By using an air hose or other tools, the debris can be safely removed from a distance. If, however, the employee needs to reach in to remove the debris by hand, he/she must lockout the equipment to block the head from falling.