Thursday, May 26, 2016

Lockout/Tagout (LOTO)

Lockout/Tagout: Grim Consequences of Ignoring OSHA Standards


When it comes to working on car wash equipment at the wash, effective Lockout/Tagout (LOTO) procedures are crucial. Having these procedures in place not only complies with OSHA standards but, more importantly, can prevent serious injury or death.

For those of you that aren’t familiar with what a LOTO program is, review OSHA Subpart J, 29 CFR 1910.147 “The Control of Hazardous Energy.” This procedure establishes minimum standards for Lockout/Tagout at a facility. The goal of the program is the prevention of accidents caused by the unintentional energization of equipment or release of stored energy. An employee isolates an energy control device by applying a lock or tag to the device in the off, or safe, position, indicating that the control cannot be operated. Note that energy sources do not have to be electrical only. For instance, an air compressor would qualify as well.

The following are some headlines that provide real life examples of the consequences of not providing a proficient LOTO program at car wash locations:

  • A Car Wash Attendant Dies When Pulled Into a Side Arm Rotating Brush in a Car Wash - 2016
  • Jason’s Story: Electrocuted and Died in a Car Wash - 2014
  • Teen’s Leg Gets Stuck in Carwash Equipment – 2014
  • Car Wash Employee Gets Foot Caught in Conveyor - 2013
  • Man Loses Leg Cleaning Wash - 2011

Having a LOTO plan in place does not automatically mean that your car wash has all the components for compliance. Some of the owners in the cases above felt that they had protected their employees by implementing a LOTO plan. However, after investigating the circumstances behind a few of these incidents, it was learned that you can sometimes comply with the letter of the law, but not the spirit of the law. Case in point: In the first incident listed above, the car wash was missing a written procedure for safely performing the task that lead to the death. The employee may still be alive if the owner had taken into account other aspects and intentions of the LOTO program. The development of an audit and inspection program as part of the LOTO plan would have pointed out, in writing, the potential dangers of the procedure being performed by this individual. It would have educated the employee on the dangers associated with the job he was doing and why shutting down the power was necessary.


I recently read a Grainger article outlining a “Best Practice 5-Step Plan” that I believe will help bolster a LOTO program. It’s not just about having the locks, tags, signage and good intentions. The 5 steps are:

  1. Develop and document your energy control policy/program
  2. Create and post written, equipment-specific lockout procedures
  3. Identify and mark all energy control points
  4. Train your employees, communicate and conduct periodic inspections
  5. Equip your employees with the proper lockout tools and warning devices

It is important to note that the person who died in the first title above was performing a routine job. He was simply washing down the area around the conveyor where an excess amount of dirt and debris had accumulated. It was the process that killed this employee, not the actual hazard of this particular job!

It is human nature to take the position that we comply with regulations as well as anyone can be expected to. After all, we are responsible people doing the best we can to keep our employees safe. But, we also need to continue to question ourselves and keep an open mind to constantly evaluate if there is more we can do.  It is following the spirit of the laws that will truly keep our employees safe and alive.

Take another look at your LOTO program and decide if it will meet all the criteria necessary to protect your employees while working at the wash. If you don’t already have one in place, work with your insurance provider to get one. Do it today because tomorrow may be too late.


Remember: A Safe Wash Protects People and Profits!

Thursday, March 24, 2016

Safety and Hazards


The success of any safety initiative, with regards to hazards at the wash, begins with the obvious. Too often, problems are overlooked because we become accustomed to their presence on a regular basis. For example, some areas of the wash may become compromised by transfer from the chemicals at the exit. Employees see the discoloration all the time and may think nothing of it. However, added substances can make parts of the property more susceptible to slip and falls, leading to increased liability.


One way to combat this issue is to institute a process of having an employee perform a walkthrough of the wash every day before opening for business. It is also recommended that this person be rotated periodically to ensure you occasionally have new eyes and a different perspective. Create a simple form to record any problems your employees may detect. For example:


Creating a process is the first step, but it is then imperative to provide employees a forum where they can share what they have observed. Finally, any hazards that are identified as dangerous to employees or customers must be corrected immediately.

In the example mentioned earlier, power washing the affected areas regularly may be the logical solution to minimizing the potential effect of the slippery surface. I think everyone will agree, this is a very easy and cost effective procedure to implement. So, ask yourself, does your wash review and implement safety initiatives on a regular basis? If not, incorporate a plan to start right away.

An example of a consequence when these things are overlooked can be found in the following link:

Also, please visit my earlier blog posted in February of 2014 titled “What is a Crushed Foot worth?” Outlined in that post is a detailed explanation of how to develop a formal hazard assessment program.

The bottom line is that developing proactive measures to avoid unintended injuries at the wash is worth the investment every time! Please don’t overlook the obvious and be sure you have a plan in place now.