Does Your Lockout/Tagout Program Need to Evolve?

Lockout/Tagout (LOTO) programs have become a common practice for safeguarding employees. Yet the incident rate of electrical workplace injuries has remained relatively unchanged over the past decade. According to a new study conducted by EHS Today and Panduit, 40% of companies have reported electrical incidents over the past five years and nearly seven out of ten have reported near misses.1


The Hierarchy of Risk Controls is used to determine how to implement feasible and effective control solutions. Control methods at the top of the graphic are potentially more effective and protective than those at the bottom.

Many LOTO programs aren’t as effective as they should be because they are still primarily focused on manual risk mitigation at the lower tiers of the Hierarchy of Risk Controls—PPE and administrative controls—which are considered the least effective methods for preventing electrical incident injuries and fatalities.

To truly minimize hazards, your LOTO program likely needs to evolve to focus on the higher tiers of the Hierarchy of Risk Controls, and doing that requires collaboration and input from across the organization.

Common Shortcomings

PPE is only effective if worn properly, yet a study of construction workers found that although 82% of participants believed wearing PPE could protect them from injury, 58% of participants were reluctant to wear it and 53% reported seeing coworkers without it in dangerous situations.2 The time it takes for a worker to determine what PPE is required, obtain and inspect it, and then put it on is significant, especially when workers are under pressure to meet deadlines. Even after all that, PPE doesn’t do anything to prevent hazards in the first place.

When servicing electrical equipment, workers must comply with safety regulations that require a voltage verification test to validate the absence of voltage. This process includes a number of stages that can be complex and time-consuming when using hand-held portable test instruments.

Employees performing Lockout/Tagout procedures must verify the absence of voltage in order to establish an electrically safe work condition.  However, using traditional methods with a manual voltage testing device still exposes workers to electrical hazards. One survey found that over a five-year period, 55% of respondents reported either an injury or an injury near miss with voltage test instruments at their facility, and 11.7% reported a disruption to plant operations.3 The underlying causes identified included hardware deficiencies, human error, and inadequate systems for managing the selection and use of the test instruments.

The manual voltage testing process itself relies on the expertise and diligence of the person doing it. The process has been described by some as “easier said than done,” with one survey at a large chemical company finding that 90% of the organization’s electricians and technical personnel did not know how to perform a thorough test.4 Manual processes are difficult to track and leave the person performing the task on his or her honor to execute each step; there are no warnings or indications if a step is forgotten or skipped.

Moving Up the Hierarchy of Risk Controls

The NPFA 70E 2018 standards now explicitly state that the priority of any safety program needs to be the elimination of the hazards. Two areas of improvement in particular can go a long way in moving the focus of your LOTO program from mitigation toward elimination.

Collaboration

Reducing hazards isn’t possible without all employees adhering to the program, and safety procedures can’t be developed in a vacuum. That’s why the most effective LOTO programs are built in collaboration with multiple departments. In addition to helping increase buy-in, attacking a problem from multiple angles can reveal hidden stumbling blocks and provide new insights for overcoming them.

It’s also important to keep in mind the different groups of employees affected by your LOTO program:

  • Authorized employees, who are responsible for implementing energy control procedures and performing the required servicing or maintenance.
  • Affected employees, who operate equipment or work in an area in which an energy control procedure is being implemented.
  • Other employees, including office or warehouse personnel who work in an area where an energy control procedure is utilized.

Each group must understand their purpose and role in the LOTO program. For example, while affected employees are not responsible for locking out or tagging out, they need to clearly understand not to start up or use equipment during these procedures.

Bringing each group to the table to gives them a real sense of ownership over the program’s design and ensures that all teams understand, support, and follow the proper procedures.

Safety Technology

The more manual steps you can eliminate from any process, the more you can reduce exposure to possible risks and potential individual errors. This is especially true for a LOTO program that depends on using handheld testers for voltage verification, which expose the person performing the test to the very electrical hazards they are trying to avoid.

Incorporating more engineering control technologies moves your LOTO program up the Hierarchy of Risk Controls by creating barriers between workers and electrical hazards.

The VeriSafe™ – Absence of Voltage Tester minimizes risk by verifying the absence of voltage before equipment is accessed, making it easier for qualified electrical workers to verify an electrically safe work condition has been established.

One example of an engineering control solution is Panduit’s Absence of Voltage Tester (AVT), a device that can be permanently mounted on a control panel and that can indicate if the panel is de-energized before opening.

As with any process, the easier your LOTO procedures are to implement, the more likely they will be followed. Anything that can reduce the time needed to look for proper tools, devices or PPE should be considered. This can be as simple as having dedicated lockout kits or lockout stations.  Another option is to use lockout devices that can be installed without tools, such as Panduit’s PowerLOK™ circuit breaker lockout device.

Finding the Right Partner

Research has proven that just having a LOTO program in place isn’t enough to protect your employees and business from the risks associated with electrical hazards. Today, it’s crucial to strive for the more effective, higher tiers in the Hierarchy of Risk Controls. Yet, evolving a LOTO program to reduce hazards can seem overwhelming.

That’s why at Panduit we work closely with you to understand the unique needs of your business. In addition to offering industry-leading safety solutions, Panduit can also help your organization with safety services and OSHA-compliant training to help you build a better, more effective LOTO program.

For more information on how to improve your electrical safety programs, read our eBook How Understanding the Hierarchy of Controls can Lead to Reduced Electrical Incidents.

FOOTNOTES:
1 EHS & Panduit: Industry Insights: Electrical Safety Considerations: https://bit.ly/2W3XHlD
2 R. U. Farooqui, S. M. Ahmed, K. Panthi, and S. Azhar, “Addressing the issue of compliance with personal protective equipment on construction worksites: a workers’ perspective,” in Proceedings of the 45th ASC Annual Conference, Gainesville, FL, 2009.
3 H.L. Floyd and B. J. Nenninger, “Personnel safety and plant reliability considerations in the selection and use of voltage test instruments,” IEEE Transactions on Industry Applications, vol. 33, no. 2, pp. 367–373, 1997.
4 K. Crawford and N. K. Haggerty, “Test before touch: Seems easier said than done,” IEEE Industrial Applications Magazine, vol. 14, no. 3, pp. 32–39, May/ June 2008. doi: 10.1109/mias.2008.918503.

Troubleshooting Safely: Using PtD Methods to Provide Safe Access to Energized Equipment

Control of Hazardous Energy – Lockout/Tagout has once again appeared on the Occupational Safety and Health Administration’s (OSHA) Top 10 Most Cited Violations in 2018. Although this category covers a wide range of violations, it confirms that personnel continue to pursue access into electrical enclosures without being fully aware of the danger involved. Before performing electrical work, OSHA and the NFPA 70E Standard for Electrical Safety in the Workplace both direct workers to de-energize circuit parts to which an employee may be exposed, but why would a worker attempt to access an electrical enclosure without first ensuring that the enclosure is de-energized?

In an increasingly connected and intelligent plant floor, the need to maintain, monitor, or troubleshoot Programmable Logic Controllers (PLCs), motors or Variable Frequency Drives (VFDs) in an electrical enclosure is exponentially increasing. As more and more of this technology is designed in to equipment today, the personnel required to service this technology expands beyond the standard qualified electrician role and into roles inhabited by machine operators, IT personnel, and others. But whether it’s a qualified or unqualified electrical worker, opening an energized electrical enclosure poses the same serious safety risks.

Even though there is inherent risk in opening an energized electrical enclosure, performing service work without power in the equipment is prohibitive to diagnosing or monitoring the equipment. This poses the question: how does a worker safely operate in a potential electrically unsafe work environment and still perform the duties they are assigned? This conundrum has challenged equipment designers to standardize on a solution that allows for personnel who are not electrically qualified to access networks or systems within an electrical enclosure without risk of exposure to hazardous electrical conditions.


APPLYING PtD AND THE HIERARCHY OF CONTROLS TO THE ISSUE

In order to combat this challenge, more and more designers have employed a methodology called Prevention through Design (PtD) when developing products. According to The National Institute for Occupational Safety and Health (NIOSH): “Prevention through Design encompasses all of the efforts to anticipate and design out hazards to workers in facilities, work methods and operations, processes, equipment, tools, products, new technologies, and the organization of work. The focus of PtD is on workers who execute the designs or have to work with the products of the design . The initiative has been developed to support designing out hazards, the most reliable and effective type of prevention.”

Hiearchy of Controls infographic
Hierarchy of Controls infographic by NIOSH. The most effective control methods are located at the top with the least effective at the bottom.

It is interesting to note that NIOSH states that “designing out hazards” is the most reliable and effective type of prevention. This is a core concept that is also shared in the hierarchy of controls system. As represented in the graphic, Elimination (physically remove the hazard) appears at the top of the pyramid and corresponds with being the most effective method of hazard prevention. Substitution (replace the hazard), Engineering Controls (isolate people from the hazard), Administrative Controls (change the way people work), and PPE (protect the worker with Personal Protective Equipment) follow Elimination in a descending order from most effective to least effective, respectively.

Returning to our challenge to standardize on a solution that allows for personnel to access networks within an electrical enclosure without risk of exposure to hazardous electrical conditions, we can apply the Prevention through Design methodology by employing the hierarchy of controls. Since Elimination is the most effective method to design out hazards, the solution to our challenge would be to completely remove any energy within the electrical enclosure. Unfortunately, in this case, removing all energy from the enclosure is prohibitive to diagnosing or monitoring the equipment within, so Elimination is not a practical or reasonable solution to our challenge.

Working down the hierarchy of controls pyramid, our next option is Substitution, the second most effective hazard control. Substitution involves replacing something that produces a hazard with something that does not produce a hazard. For our challenge, Substitution would seem to suggest that we either replace the energized enclosure with a de-energized enclosure, develop a PLC or VFD that somehow doesn’t require energy to operate, or create a separate panel for the PLC without any hazardous voltage. Again, it is impractical to entertain any of these substitutions as viable solutions to our challenge.

This leads us to the next option: Engineering Controls, the third most effective means of controlling hazards. Engineering Controls do not eliminate hazards, bur rather isolates people from those hazards. Isolation involves creating a physical barrier between personnel and hazards and this option seems to have potential. If there were a way to access the PLCs and VFDs in our electrical enclosure without having to open the door to the enclosure and expose the worker to significant risk, we could achieve the most effective hazard control that is practical to our challenge.

A FRESH APPROACH TO A MODERN NEED

Panduit Data Access Port

Isolating personnel from the risk of opening an energized electrical enclosure to access the intelligence inside has led to the development of the Panduit Data Access Port (DAP). The Panduit DAP is mounted on the outside of an electrical enclosure and provides programming ports as well as electrical outlet access without the need to open the enclosure. This allows personnel safe access to PLCs, VFDs, and other internal components without the risk of exposure to electrical hazards. With the Panduit DAP, a practical and successful solution with the most effective hazard control possible for the application has been attained.

While connected and intelligent plant floors continue to develop at the speed of light, there are additional aspects of new technology that often go overlooked. As OSHA’s Top 10 Most Cited Violations has indicated, electrical safety can be an afterthought, but planning for safety should be an important first step when developing new processes or products. The Panduit Data Access Port is designed from the beginning to provide the most effective safety control while still allowing personnel to complete their tasks. Even as intelligent plant floors develop faster than we realize, creating a culture of safety should always move equally as fast.

For more information on Prevention through Design methodology, read our whitepaper.

For more information on Panduit Data Access Ports, visit www.panduit.com