Hazardous Energy Management: Why Control Isn’t Enough

Introduction

Most of those in the safety field are familiar with the terms control of hazardous energy, LOTO, or lockout/tagout. These are a few of the names associated with company-specific written programs, compliance-based training curricula, annual audits, and regulatory documents on this subject for decades.

Despite that familiarity, effective implementation of these principles is not universal, nor is it flawless. Employees are injured, OSHA citations are issued, and fundamental aspects of the process still aren’t understood, communicated, or executed effectively. Together, those factors add up to one thing: failure. Failure to protect employees, comply with regulations, and effectively manage the Hazardous Energy Program.

You can probably tell I take a nontraditional approach and use nontraditional language to describe the “control of hazardous energy.” There is a very intentional and strategic reason I use the phrase “Hazardous Energy Management” instead. The goal is to challenge your current mindset and lockout program by transforming it from a noun—describing the policy as a thing—to a verb: an initial and ongoing action, or a state of being.

The name of the program is, of course, subjective—titles are simply lexical semantics. What matters is the objective aspect of an effective Hazardous Energy Management program: the universal understanding that protecting employees requires an active, ongoing management approach to hazardous energy. Performance beyond compliance, compliance itself, insurance cost savings, and other benefits are simply byproducts of doing what it takes to protect employees.

Fundamentally, the terms “lockout/tagout” and “control” confine the comprehensive requirements of a hazardous energy program to just control—the padlock—and communication—the tag. Regulations further narrow the scope to service and maintenance activities.

Hazardous energy management is a more comprehensive approach—one that accounts for every circumstance in which employees can be exposed to hazardous energy throughout the course of work. During routine production, this looks like machine guarding. During service and maintenance, it looks like traditional lockout/tagout.

What does it look like for setup operators? For troubleshooting a fault? Do you need protection for corded or battery-powered equipment when changing bits or blades? These are all questions I hope you can answer by the end of this article.

The Performance Standard

A performance standard holds you accountable for a particular outcome—not for the specific equipment, design, or method you use to arrive at an effective result. Common practice for most organizations is to focus on a specific machine or operation to check a compliance box. They identify the active sources of energy and document the proper shutdown as required by OSHA regulation. This practice is known as generating Energy Control Procedures, or ECPs, for use during service and maintenance activities.

Many of you who are familiar with OSHA regulations also know about exemptions to the use of lockout/tagout and the development of ECPs. These exemptions include testing and positioning, as well as minor servicing. Misunderstanding these exemptions can create a gap in employee safety—and in meeting the performance standard—if hazardous energy isn’t managed correctly.

Make no mistake: an OSHA exemption doesn’t relieve an employer of the responsibility to protect employees. An exemption may waive the formal lockout or ECP requirement, but only “provided that the work is performed using alternative measures which provide effective protection.”

Alternative measures are flexible and may differ based on equipment and production requirements. That can mean implementing effective interlocks when lockout/tagout isn’t possible. It can be a rule requiring employees to maintain control of the plug for the corded equipment they’re using—literally keeping it in their pocket—to prevent unintentional startup.

It can also involve setup procedures, troubleshooting procedures, operating a robot in T1 teach mode using the pendant, work instructions, or standard operating procedures that identify appropriate protection methods when an employee may encounter hazardous energy. There’s flexibility in how you accomplish this, but there is no exemption from an employer’s duty of care or from meeting the performance standard.

Performance Measurement

Performance measurement is the process by which we prove that the method used provides reliable, effective protection against employee exposure to the hazard under actual working conditions. We can use risk assessments to formally and quantitatively measure risk reduction.

As a preliminary benchmark, take a few minutes to reflect on your own operations and management program:

• Are you currently identifying both types of energy—kinetic and potential?
• Are you confident that employees know how to effectively protect themselves and achieve a zero-energy state when no energy control procedure is provided or required?
• Does your training program teach employees how energy can reaccumulate in a machine?
• Do your ECPs identify methods for releasing or blocking potential energy?
• Are you using remote monitoring technology to test, position, and monitor equipment while employees remain at a safe distance?
• Are employees trained to identify passive energy sources and the risks of stored energy, such as pressure-injection hazards, mass, and gravity?
• Is your energy control program included in confined-space training and qualification for entrants?

If the answer is “no” to any of the above—or “I’m not confident”—it’s probably time to revisit your written program, training program, and annual audits to ensure you’re effectively managing the following eight pillars.

These pillars divide into four strategic and four tactical management steps necessary to provide effective employee protection and diligently manage a hazardous energy program that meets the performance standard.

The 4 Strategic Pillars of Effective Hazardous Energy Management

1. Written Programs — A formal policy in writing is not just a regulatory requirement; it’s foundational to the next three steps. The written program is the standard for managing hazardous energy in every circumstance and should include ECPs, setup procedures, and work instructions or standard operating procedures to ensure employees have adequate guidance in every exposure scenario.
2. Communication — Training employees on the content of the written program is the next strategic step. Training must be documented for everyone who can be exposed—not just authorized and affected employees. Contractors, visitors, and vendors need this information too, in accordance with OSHA’s Multi-Employer Citation Policy.
3. Auditing — Monitoring the program’s effectiveness and identifying gaps is necessary to continuously improve and catch leading indicators before they become injuries. An investigation is simply an audit conducted after something has already gone wrong. It may be necessary after an incident, but it’s not the most effective way to proactively manage and prevent hazardous energy injuries.
4. Continuous Improvement — When an audit surfaces a problem, improvement is what you do about it—retraining, installing a bleed valve, disciplining an employee, purchasing more lock adapters, and so on. Audit results will rarely be perfect, and that gap is the opportunity to improve your program and reduce employee risk.

The 4 Tactical Pillars of Effective Hazardous Energy Management

1. Identify and Isolate — Do you have kinetic or potential energy? How many sources? Where is the mechanical device that interrupts that energy flow? Every energy source needs to be identified according to frequency and severity. The flow of kinetic or potential energy should be mechanically disconnected or blocked to prevent kinetic energy—or potential energy becoming kinetic—from contacting an employee.
2. Dissipate, Block, or Release Potential Energy Sources, If Applicable — The previous step identifies energy sources and isolates them. This step takes any potential energy identified in step one and prevents it from becoming kinetic. That usually requires action—blocking, bleeding, or dissipating the energy. Valves, bars, and other devices can be permanently retrofitted to ensure safe, consistent methods are available to authorized employees.
3. Control and Communicate — This is the notorious lockout/tagout portion. Plenty of hasps and adapters are available on the market, and nearly any mechanical isolating device can be controlled with an adapter that accepts a padlock. Tags communicate to unauthorized employees that risk and energy are present—or potentially present—and that they and their coworkers are at risk if those controls are removed.
4. Verification — The final, and most important, step is to verify or test. Methods vary depending on the type of energy present, but the principle is the same: confirm that the energy isolated and dissipated in steps one and two was addressed properly. It’s a cheap insurance policy against becoming a lagging indicator. Don’t overlook nuisances such as dysfunctional pressure gauges, inaccurate meters, Variable Frequency Drives with charged capacitors, or control buttons that can create a false zero-energy reading.

For more information, or for assistance reviewing or developing your Hazardous Energy Program, training curriculum, annual audits, ECPs, or other safety-related needs, reach out to Bolster Safety Craft.

Our goal is to support and strengthen your Hazardous Energy Management program through baseline performance standards and performance measurement, ensuring predictable outcomes.