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:
- Develop and document your energy control policy/program
- Create and post written, equipment-specific lockout procedures
- Identify and mark all energy control points
- Train your employees, communicate and conduct periodic inspections
- 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!