As elaborated in the book “Manage Health & Security; Get the Best… Prevent the Worst” by Marc-Andre Ferron, the basis for proper health & safety solutions management is to identify the risks within your company and make sure you are compliant with all the applicable rules and regulations. Lockout, beyond being a requirement in several EHS standards worldwide, is a key element to both the Health and Safety of workers and operational efficiency. The underlying reason that lockout is often identified as the first control method to be instated during the risk identification period is simple and can be illustrated by the hierarchy of preventive measures:
As stated above, eliminating the hazard is the most efficient way to control a risk, and lockout, when properly implemented and managed, is the simplest and most efficient way to control the energies associated with the hazard. The major normative principles are all based on the Plan-Do-Check-Act formula and a project to implement a lockout management system is no exception. When properly managed, it guarantees the physical integrity of workers and significantly reduces the time required to control hazardous energies. For many companies, lockout management is limited to procuring accessories (locks, boxes, mechanisms, etc.) and/or having a set of well documented procedures, easily accessible by the workers and with its content up-to-date. These aspects, although very important, are in fact only a few facets of an overall lockout management. Let us look at all the necessary elements to make a lockout implementation successful.
The first step in the integration of a lockout system is to establish clear rules and guidelines. It would be impossible to play Monopoly without establishing the “house rules,” so why should it be any different when it comes down to a worker’s safety? From the roles and responsibilities of each stakeholder to the colors of padlocks to be used, the program is used to regulate the lockout practices within the company. This program, far from being a shelved document after being drafted, must stay alive and must be periodically revised to reflect the goals and best practices of your business.
In order to simplify the application of procedures in the field by employees, it is recommended to tag each of the items listed on a lockout procedure with a standardized and unique number. The tags used should be durable and easy to spot in the working environment. This action enables the employees to ensure the correlation between the steps mentioned in the procedure and the device to be operated in the field. It also allows them to significantly reduce the time it takes to perform their lockouts.
The next step is usually the development of lockout procedures. Either developed by areas, by equipment or by systems, the procedures must detail the steps required to control the hazardous energies to which the worker may be exposed while performing a job. When developing lockout procedures, it is important to take into account both internal and external elements in the work area. All lockout procedures should normally be verified by a competent person and the final document should be approved by a company representative (supervisor, manager, etc.) before being used in the field. The information contained in each of the procedures must also be reviewed periodically.
As the saying goes, “We cannot control what we do not measure.” It would be, therefore, impossible to say that we are in full control of the lockout if we do not take the time to periodically observe how it is doing out on the plant floor. Several types of observations can be performed to evaluate compliance with the established lockout program:
The data compiled from these observations allows management to provide appropriate feedback to the workers and make the necessary adjustments if deviations are noted.
Many companies feel the need to “be good” at performing lockout before starting to observe it. While it caters to our ego to see some positive numbers on those first observation reports, the complete opposite should be done. By starting the observation process at the system go live, it is possible to identify and address the deviations before they become bad habits, ultimately making the time required to become good shorter.
The usage statistics of procedures and other documents related to lockout can also provide crucial information about the global health of the system you implemented. Once analyzed, the data can provide a predictive model that will lead to a global optimization of the system and its sustainability.
If the selection of preventive measures for a task is limited to lockout, there might be cases where performing a lockout may prevent the execution of the task in question. Let us think, for example, of all the tasks that are considered an integral part of the operational process like the troubleshooting or commissioning of an equipment. These tasks, which are usually performed by qualified and competent staff, sometimes put the workers in the presence of an uncontrolled, hazardous energy. This type of work should be thoroughly analyzed to identify the risks to which the worker is exposed and the results of the analysis should be communicated to the affected employees. Corrective measures may range from the simple use of personal protective equipment (PPE) to the development of special tools or guarding that must be implemented to ensure the physical integrity of the worker.
Where the risks associated with a task cannot be controlled by applying a lockout procedure, it is necessary to inform employees of the control measures implemented for their safety and physical integrity. The safe work procedures or standard operating procedures will enable the worker to know all the risks that are present during the execution of the task and provide him with a list of all the steps he needs to perform to reduce said risks to an acceptable level.
There are several elements to be implemented for an overall lockout management within a company. This non-exhaustive list of elements to be implemented demonstrates that the lockout, although generally considered a simple aspect of EHS, is a multifaceted process. The integration of all these elements should help your business meet the standards and regulations, and should provide your company’s EHS culture the flexibility to establish a safe working environment while still keeping operational optimization a priority.