Common Pitfalls of Lockout/Tagout 29 CFR 1910

Common Pitfalls of Lockout/Tagout29 CFR 1910.147

Daniel Hammonds

Safety, Security & Environmental Manager

Kraft Foods – Coshocton

April 7, 2009

Agenda

• Kraft Foods – Coshocton background

• What is lockout?

• 7 Steps of lockout

• Where can we fall into trouble?

• How do we avoid the issues?

• How do we train our employees?

• How do we implement LOTO programs?

• How do we manage our programs?

Kraft Foods - Coshocton

• Located in Coshocton, Ohio

• 180,000 square feet

• Oscar Mayer business unit

• Large producer of retail sliced bacon

• Over 400 union employees

• 24/7 Operation with sliced bacon packaging lines

• 70% reduction in OSHA rate over last 5 years

What is Lockout?

•Lockout/Tagout (LOTO) refers to specific practices and procedures to safeguard employees from the unexpected energizationor startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.

– OSHA

Pitfalls of Lockout

• How do we protect our employees while they are in areas of danger?– 7 Steps of Lockout

• What are the areas for concern?– Interpretation– Implementation– Management

• How do we train our employees in lockout and how do we manage the program?– Kraft Foods – Coshocton’s processes

7 Steps of Lockout

1. Prepare for shutdown– Review procedures– Notify affected employees– Locate all disconnects

2. Shutdown the equipment– Follow the procedure exactly– Stop machine normally

3. Isolate all energy sources– Physically isolate all energy sources

7 Steps of Lockout

4. Apply locks– Unique locks for lockout– One person, one disconnect, one lock– All locks secured

5. Release stored energy– Zero energy state

• Bleed lines, lower die blocks, discharge stored electricity

6. Verify equipment isolations– Attempt to restart machine

• Return to off position

7. Complete, Remove and Restore– Finish work

• Inspect for tools, parts, etc.• Replace guards, notify affected employees• Remove locks

Where do we fail?

• Interpretation

• Training

• Implementation

• Management

• Accountability

Interpretation

• Maintenance

• Sanitation

• Tooling Changes

• These are the easy ones…

The pitfalls of Lockout?

• What does routine, repetitive, and integral to the use of the equipment for production really mean?– What kinds of guards can be removed, or can they?– Clearing jams deep inside a machine?– Micro swabbing?– What about control reliability of interlocks?

• Cat. 3 Safety Circuits?

• Does your facility have jam clearing procedures?– Can be part of process documentation– Are they followed?– Are they enforced?

How do we avoid the issues of interpretation of LOTO?

• Documented procedures

• Training– With Understanding

• Certification

• Accountability

• Review

Documentation and Procedures

• We all have Lockout procedures– Reviewed annually by safety and maintenance

• Kraft Foods – Coshocton also has Detailed Process Sheets (DPS)– DPS’s are created for each job function

• Used for training and job certification• Performance standards

– DPS’s include machine safety awareness• Pinch points• Jam clearing• Other potential hazards

1)Hair net and beard net are for GMP purposes. They can be found in the main hallway between the green room and entrance to the saran lines.2)Hard hats are needed for protecting head.3)Hearing protection is required in production areas. Noise levels are above those permissible by OSHA. Ear plugs can be found in the main hallway between the green room and entrance to the saran lines. You may also wear ear muffs provided by safety technicians.4)Safety glasses and goggles are required to protect your eyes from flying particles and chemicals used in sanitation. Safety goggles must be worn during foaming. Safety glasses may be worn at all other times.

1.Head protection

1.Chemical proof jacket2.Chemical proof overall pants3.Slip resistant rubber boots4.Safety goggles (face shields also available)5.Safety glasses6.Hair net7.Beard net (if necessary)8.Hard hat9.Cotton gloves10.Green gloves11.Hearing protection

1.Personal protective equipment specific to sanitation

Pictures / DrawingsOperational AnalysisMain Steps

DPS Example

Training

• At Kraft Foods – Coshocton, our hourly employees are the trainers!– Trainers have attended train the trainer programs and

leadership training• Employee empowerment and job enrichment

• Hourly safety technicians train all hourly employees in lockout– New Hire Orientation– Initial program training

• Employees transferring into jobs with LOTO requirements

– Annual review training– Assist in the development of the procedures

Training

• Annual lockout certifications– Every employee in the lockout program has to be certified at

least annually to ensure understanding of program• Review of training materials• Observation of machine lockout• Quiz

• Review machine lockout procedure accuracy– Every machine and procedure is reviewed at least annually

More Training

• Who gets the training?– Authorized

• Maintenance• Sanitation• Machine operators

– Affected• Everyone else

• Supervisor Training– Are your supervisors lockout trained?– Do they all know what lockout really means?– Are they holding employees accountable?

Implementation

• How do you determine who will be an authorized employee?– At Kraft Foods – Coshocton all machine operators are LOTO

certified– Maintenance– Sanitation– Supervisors and most Salaried

Implementation

• Each authorized employee is assigned a lock or lockset– Only one key is issued for each lock

• No spares or reserves are kept

– Information is maintained in database for lock ID #’s• Database also used for training needs identification

Management

• Managing a LOTO program is paramount to keeping employees safe

• Does your facility have group lockout programs?– Kraft Foods – Coshocton uses multi-position hasps for group lockout

• How do you handle shift changes?– Employee can not leave for their shift until the next employee places

lock onto equipment, or– Equipment is returned to a guarded state prior to exit

• What happens if a lock is left on a machine?– Lock cutting procedure

• Every situation is unique, and one solution doesn’t work for all facilities

Management

• New machine reviews and commercialization

• Do you have a documented program for identifying lockout needs for new equipment?– Risk Assessments– Have you included maintenance and sanitation issues?– Do you understand the process flow of the machine?– How are you going to clear jams?– Are you going to need guard interlocks?

• Cat. 3 or better.

• Vendor support– Working with the equipment manufacturers from the beginning of the

process will help identify solutions early

• New equipment goes through an extensive safety review prior to installation and commercialization

Management

• At Kraft Foods – Coshocton:

• One supervisor and one safety tech are charged with “owning” the LOTO program– Keeps the machine checks up to date– Ensures training and re-training of all employees– Ensures certifications are completed on time

• All supervisors are accountable for the safety of their employees– Safety targets are included in all company Key Performance

Indicators– All meetings begin with safety

Accountability

• All Kraft Foods – Coshocton employees are responsible for their own safety– Never put yourself at risk– Got Your Back Program

• Peer to peer evaluations and watching out for other employees

• Unsafe actions by employees must face consequences– Kraft Foods – Coshocton has a ZERO tolerance policy for

failure to lockout– If you do not lockout the machine, you do not have a job with

Kraft Foods• Two employee terminations for LOTO failures

– 30 year employee– 6 year employee

A few final words

• No single lockout program will work for all operations

• Many specifics of facility lockout programs are unique and don’t fit in all programs

• Always question what you do and ask, how can we get better?– Continuous Improvement

• Engage your employees

• A few minutes of downtime is not worth someone’s life

Thank You!

Any Questions?