The control of hazardous energy is a difficult safety topic. This is especially important for maintenance and construction staff. As a result, the Occupational Safety and Health Administration (OSHA) has created the Lockout Tagout standard (29 CFR 1910.147). This standard provides guidance for the following:
- OSHA Lockout Tagout procedures for authorized employees
- Requirements for employees working around energized equipment using locks (affected) and those applying locks (authorized)
- Training requirements for all employees roles
While the standard does provide a clear outline for various lockout tagout procedures, it does not outline the best methods to train each of your employees. We would like to explore some areas you should consider when selecting the appropriate method to train your employees. This will help ensure that you meet two very important objectives. First, that is that you do not have any accidental equipment startups. Second, your employees should be well aware of the predominant electrical hazards in their workplace.
Off the Shelf Training Courses
There are many lockout/tagout training options available for companies to use. Most vendors offer lockout tagout training as an off the shelf training course. The primary goal is to train to the OSHA standard, and provide material in an instructor-led or e-learning format. As a result, the training will cover every type of lockout tagout and the basic methods that are used. It will then be the responsibility of your training team to identify the relevant material from the course, determine how to incorporate the company lockout tagout procedures, and build training for the company-specific procedures and equipment.
Develop a Course Internally
A very common method is to develop a lockout tagout training from an existing policy or procedure. This is typically completed by the safety team. Alternatively, it will be a collaborative effort with the safety and training teams. I have seen this method applied broadly as an hour long training session to an entire department, most of which are only affected employees. I have also seen much more specific trainings offered to 2-3 employees at a time. The key with OSHA lockout tagout training is understanding who needs what training, then optimizing a class schedule to train all of the employees on their respective lockout tagout roles (affected or authorized).
Recurrent Training
As the standard describes,
“Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures.”
oshatraining.gov
This means that employees only need initial training. Recurrent training is only required if procedures and/or processes change. This is quite uncommon. At SEED, we recommend an annual lockout tagout training. This is to emphasize the importance of applying lockout tagout correctly to ensure all the employees remain safe. There are several options for annual training that companies have employed successfully:
- If you have used an off the shelf training course, you may be able to re-purpose it for a quick micro-learning
- Provide an e-learning module (approximately 15 minutes in duration) to your employees on an annual basis
- Provide a blended learning for their initial training, and the e-learning portion will be taken annually thereafter
Equipment-Specific
One area where we have identified many gaps is the lack of equipment-specific LOTO training program. Often times, the policy and procedures are written and coupled with an a vendor lockout tagout program. As a result, employees are given the training requirements of the OSHA lockout tagout standard and an introduction to a company policy. There are many differences in company lockout tagout programs such as:
- Group lockout tagout procedures vary or are not used
- There is a variety in lockout tagout equipment and how they should be applied to the equipment
- Company-specific safety protocol are not fully understood
Variance Within the Regulations
We have worked with many clients developing custom lockout tagout training. For one client, their policy dictated to use specific locks for specific equipment. Another company did not allow lockout tagout to span longer than one shift. And another client had very specific requirements for backup keys. They are all following the regulation, but had implemented the lockout tagout programs in different ways. As a result, their initial lockout tagout training course did not meet the needs of the training participants. They were trained to the standard, but still had questions about the specific procedures that the company used.
These are just a few considerations you should evaluate when determining how to setup your lockout tagout training. You will want a training course which is efficient for your employees and practical for their area of expertise. Additionally, the training will need to provide them with both the regulatory requirements and the company specific policies which are aligned with the OSHA regulations.
