A Whole “LOTO” Love

February 6, 2014 No Comments

Since the inception of OSHA’s regulations for the Control of Hazardous Energy (29 CFR 1910.147) it has consistently ranked in the Top 10 most cited violations. Lockout / Tagout (LOTO) is a fairly simple process, but even the simplest process can be a burden when multiplied by thousands.  That is the exact nature of the burden: this simple process must be done for every switch, breaker, valve, flange, and etcetera, in what may be an extremely complex piece of equipment.  This leads to tedium, which often leads to shortcuts.  Shortcuts, of course, are statistically the 2nd most common source of violations.  OK, I made that part up, but you get my point.  It is my opinion that the simpler a process, the easier it is to discount or even disregard.

I have heard stories of operators that would rather go out in the heat here in Texas and make preparations for a shutdown than stay in the A/C and hand write LOTO tags.  It is a tedious, burdensome process that is, nonetheless, required by federal law.  Beyond the legal ramifications, we are all bound by the need for a safe workplace, and proper LOTO is a key component.  LOTO is gradually being observed more and more diligently, and many of my clients are placing it in a special EHS subset called “Life Critical Procedures”. This behavior comes from LOTO’s ability to jump the entire risk pyramid from “Lack of Training” straight to “Death”!   It’s sobering stuff that helps us refocus on the absolute necessity of proper LOTO.

Documentation is at the core of the OSHA requirement.  You must have a process, and it must be documented.  Once documented, it must be controlled to be sure no unauthorized changes occur.  Finally, OSHA requires that you review the process annually.  The problem with clearly documenting your process is that there may be multiple ways you lockout the equipment.  Now you end up creating multiple documents for the same equipment.  Now we are not only faced with lots of tags to produce, but also lots of lists to keep straight.

“Management of Change” may include the step to update lists as equipment changes, but in my experience that step is subject to manpower availability since it requires advanced knowledge of the equipment and energy isolation as well.  We frequently see folks that are energy isolation experts get passed around among units conducting turnarounds.  While the expert is in another unit, updates of lists in their typical unit may not get done.  So, when we go into places to automate LOTO and begin seeking data to populate the database, we find that typically the list that is most trusted is from the last turnaround.  

Besides the fact that documentation is required by OSHA, there is also a less obvious but potentially more important benefit of properly documenting LOTO.  That is preservation of knowledge.  The guy who has been on this unit for 32 years can lock the equipment out very consistently and safely (and blindfolded).  Next month, when he retires, that knowledge will walk out of the gate for the last time, never to return.  In a mature industry like oil and gas, the percentage of retirement-eligible workers can be as high as 40%.  We also frequently notice an age gap, where half the operators are young and half are retirement age.  Potential problems from these situations can be mitigated to some extent by preserving this knowledge and experience through documentation.  So, this mundane, tedious task carries more weight than ever.  What’s a responsible person to do?  It’s all about the tools.

As we researched equipment and materials, we began seeking guidance from operators in the industry.  What we eventually found was that printing tags is nice, but the real key to successful LOTO automation is in “data management“.  As things change, how do we maintain these lists without cluttering up the place with old revisions?  How do we handle simple tasks that must be spread across potentially thousands of items?  Our first version of our “DangerTags” product produced tags and lists but offered no help at all in data management.  Through succeeding versions, we have added lots of great features like Wi-Fi auditing, relationships to external data, and flexible tag types.  But our true innovation, and what has resulted in our system being accepted at a corporate level by two of the largest oil companies in the world, is our data management tools.

Let’s wrap up with a real-world example.  An ethylene unit in a specialty chemical plant is already conducting LOTO diligently, but they would like to add a new blind tagging system on top of LOTO.  So, on every flange in that specific unit, we want to remove the LOTO tag and add a blind tag.  Oh, did I mention that ethylene has nearly 10,000 LOTO tagging points with hundreds of blinds scattered through the various systems that make up the unit?  You can take it from here.  Here’s a hint: with smart data management, this can be accomplished with only a few clicks!–

I you’d like to learn more about our journey, visit blog.dangertags.com and to learn more about our product visit www.dangertags.com .

 

This guest article was written by Keith Davis, president of  the Application Factory, Inc. (a database programming and services company catering to the Fortune 500, particularly the petrochemical industry).  Application Factory is also the manufacturer of the DangerTags LOTO Automation System.  Keith has been automating business processes since 1987 and has lives in Beaumont, TX.     

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