Imagine having 400 machines on your shop floor, all with complicated moving parts and pieces. Everything seems to be going well. Your lockout tagout program is in place, probably sitting on a shelf in a beautiful set of binders. Then OSHA walks through the door. Their visit may not have anything to do with your machines, but they ask to see your lockout tagout program – and you’re obligated to hand it over for their inspection. Just having a plan isn’t enough. The key is to ensure your plan is compliant.
Crafting and Maintaining a Compliant Lockout Tagout Program
The smooth function and safety of the machinery in your facility is critical to your operations. To ensure that it stays in proper working order, routine maintenance and even occasional repairs are required. To address the safety of workers performing these types of tasks, OSHA introduced the Control of Hazardous Energy (lockout tagout) in 1989, and it went into effect January 2, 1989. It is estimated that proper lockout tagout programs prevent 120 fatalities and 50,000 injuries each year. So it’s no wonder that OSHA may turn its attention to inspecting these programs when on site (for any reason) in your facility.
Here’s an overview of the things to consider in your lockout tagout plan:
- Each machine in your facility must have its own set of specific procedures in place. Even if you have 70 of the same machines on your shop floor, each needs its own lockout tagout procedure.
- Your lockout tagout plan must detail how the machine will be brought to a zero-energy state, and stay there, while it is being serviced or repaired.
- Lockout tagout programs must be in place for any machine with two or more energy sources.
- Today’s shop floors can include machines powered by a variety of energy sources, including electric, air, gas, pneumatic or even gravity (think of a large, heavy dock door suddenly dropping). These power sources must be addressed.
- OSHA enforces penalties for not having a plan, or not keeping your plan compliant. These fines can be quite steep, ranging from a minimum of several thousand dollars to more than $130,000 for failure to address an issue.
Needless to say, there are many factors that must be incorporated into your plan. Once in place, training programs and proper documentation is provided. But that’s not where it ends.
French Gerleman partners with manufacturers and contractors who bring the knowledge and expertise to give you peace of mind. Our partners are experts at drafting comprehensive plans to address the needs of your specific facility.
Annual Lockout Tagout Audits
Your annual audit is the key to maintaining a compliant lockout tagout program. When OSHA arrives and asks to see your plan, they’re not only interested in knowing that you have something in place. They’re also verifying that you’re performing an annual audit. OSHA wants to know that your plan isn’t sitting idly by getting dusty on a shelf. They want the assurance that you’re revisiting the plan regularly, making any necessary adjustments, additions and reviewing the procedures in place.
This can be a daunting and time-consuming task for someone unfamiliar with the requirements and documentation. Quite frankly, it’s impossible to get through it all if this isn’t your area of expertise. That’s where the team of French Gerleman lockout tagout partners comes in. Our engineering partners have the experience, technology and knowledge needed to streamline your annual auditing and help you stay compliant. When OSHA enters the front door, you’ll have the confidence to greet them.
Lockout Tagout: Alternative Measures
A newer set of procedures that French Gerleman’s partners have been able to implement in recent years involves what’s called “alternative measures.” This has been introduced for a variety of reasons and addresses many needs and challenges you may face with the machines in your facility. Alternative measures procedures come into play when it’s simply not possible, or not ideal, to completely shut down a machine. Rather, these procedures allow for a portion of the machine to be shut down while still ensuring the worker’s safety.
French Gerleman partners will create alternative measures plans for specific pieces of equipment, provide the training and documentation, and perform the required annual audits to help ensure compliance.
Whether you have a plan in place that is in need of review or audit, or simply don’t know where to start, the French Gerleman network of lockout tagout professionals is here to help. For more information, please contact your Account Manager or contact us today.