Of all the things that can go horrifically wrong in a food plant, some of the worst are the consequences of not following lockout/tagout procedures.
Lockout/tagout (LOTO) is a system for making sure that power to equipment gets, and stays, cut off when it needs to be. That happens when it’s being installed, serviced or otherwise in a situation where it could hurt someone if it starts moving unexpectedly.
LOTO sounds basic and maybe it is, but it doesn’t get applied consistently enough. LOTO violations are the ones most frequently cited in food & beverage plants by the U.S. Occupational Health and Safety Administration (OSHA). In the period from October 2020 through September 2021 (the latest available), of the 1,188 violations issued by OSHA to food & beverage companies, 259, or 22%, were for LOTO violations.
Breaching of LOTO procedures leads to tragedies on a dismayingly regular basis:
- A 42-year-old worker at a Rich Products frozen pizza plant in July 2021 was killed when a machine he was cleaning started up. Rich was fined about $145,000 for failure to follow LOTO procedures.
- Six workers were killed when they were overcome by nitrogen gas in a malfunctioning freezer in January 2021 at a chicken processing plant owned by Foundation Food Group in Gainesville, Ga. OSHA cited Foundation as well as several of its suppliers for failure to establish lockout procedures, among multiple other violations.
- A worker at a milk processing plant in Denver owned by Safeway lost four fingers in a molding machine in early 2021. OSHA found that Safeway violated several LOTO procedures, including inadequate training, and proposed a fine of $339,379.
- An ice-cream plant in Lakewood, N.J., owned by Wells Enterprises, was cited after a worker lost two fingers while trying to service a packaging machine in 2020. The same machine had cost another worker a finger, in the same kind of accident, in 2018.
There are various reasons why LOTO procedures don’t get followed. Probably the most frequent one is that LOTO is considered “too much trouble” for something like a simple jam. It’s easy to build LOTO into scheduled maintenance with anticipated downtime. The problem comes when an unanticipated stoppage occurs.
Workers, or their supervisors, who are under a lot of pressure to keep things moving, may decide to take a shortcut rather than shut off power to an entire machine or line when a jam or some other “minor” problem occurs.
Lockout/tagout systems usually involve physical locks and tags, often customized to individuals, that attach to switches and other components. Photo: Leviton
“Responding to unexpected machine downtime can be a deterrent to compliance” with LOTO procedures, says John Garbarino, senior program manager of new technology for the commercial & industrial business unit of Leviton Manufacturing. “Statistics show that responding to these types of ‘emergencies’ often leads to taking shortcuts to get production lines running again. Safety measures often take a backseat to expediency in these cases.”
A big part of this pressure to keep things running comes from a simple lack of employees, says Andrew Lorenz, CEO of We R Food Safety!, a safety-consulting firm for the meat and poultry industry.
“At the moment I would say the biggest issue is a lack of employees,” he says. “Everyone is running short-staffed, and we are seeing a large amount of employee churn in certain areas.” He adds that management teams tend to take LOTO more seriously than employees: “They know the risk isn’t worth it.”
Employee churn means lots of new employees who have to be trained in LOTO procedures. That’s even more important for operations that routinely use temporary employees.
Write it down
Of course, before anyone can be trained, there has to be a standard procedure for them to be trained in. A surprising number of operations don’t have one, safety consultants say.
“The biggest challenge – and one of the most frequent reasons for OSHA LOTO citations – is the lack of documented LOTO procedures,” Garbarino says. The procedures should be specific to the equipment found in a plant and should be followed up with a training plan, also documented.
LOTO procedures usually involve actual, physical locks and tags that are applied to “energy sources” like circuit breaker switches. Many such energy sources are designed to accommodate padlocks, and these locks and tags often are personalized by employees. Smaller operations sometimes use what Lorenz calls “cord in hand”: Someone unplugs the machine and literally holds the plug in their hand while someone else gets into the machine. A variation is to wrap the plug in plastic tape and attach it to the machine.
“Larger clients tend to use a physical lock on the power box,” Lorenz says. “Tag usage varies a lot from plant to plant; however, larger clients tend to be more consistent with use.”
When locks and tags are used, there should be enough of them so that they’re easily accessible from any point in the plant. In many systems, maintenance workers and others who frequently need power cut off while they access equipment have personalized locks and tags that they usually carry with them.
“Making it difficult for employees to comply is another reason” for noncompliance, Garbarino says. “For example, storing locks and/or tags in an area that requires extra effort to access can deter compliance, especially for those ‘simple’ repairs. It’s better to have multiple, easily accessible, storage locations near the equipment to facilitate compliance.”
Accessibility to the power source is also an issue. Building codes in many places require electrical disconnect switches to be within 50 feet, and within sight, of any motor-driven equipment that they deliver power to. “It would be wise to follow that approach for all electrical equipment,” Garbarino says.
A digital maintenance system can help keep track of equipment that is, or needs to be, locked and tagged. Photo: Rockwell Automation
Accessibility may also be compromised when it’s unclear how to shut off the energy to a device, says JoAnn Dankert, senior safety consultant at the National Safety Council. If it takes too much time to locate the energy source or it’s too confusing, it creates a temptation to ignore LOTO procedures.
OSHA has regulations as to what can and cannot be considered an “isolating device” that reliably cuts power to equipment. Examples are manually operated circuit breakers, disconnect switches and line valves. However, pushbuttons like e-stops, selector switches and other control circuit-type devices are not isolating devices. Nor are programmable logic controllers, even though they’re often used to start and stop equipment; the problem is that they’re too liable to fail through factors like programming or usage errors, electrical surges or magnetic interference.
It’s important also to remember that LOTO applies to other potentially dangerous sources of energy besides electricity, such as compressed air, steam and even mechanical energy stored in components like springs.
Since one of the biggest reasons for LOTO noncompliance is reluctance to shut down a line for a perceived minor problem, it might help if there were procedures to safely service or otherwise access equipment without shutting off the power.
“Yes, jam clearing is always an issue/concern, but I think with some thoughtful conversations between safety/maintenance/engineering, a good resolution can be reached so the worker is protected and there is a minimization of production downtime,” Dankert says.
Digital maintenance systems sometimes enable equipment to be worked on without shutting down an entire line. Photo: Rockwell Automation
Processors in those situations should do a risk assessment to determine for which procedures full LOTO is needed and which ones can do without it, says Raul Leher, industry account manager at Rockwell Automation.
“There is a significant amount of enabling safety technology that exists today that can allow a system/machine to continue to run without being locked out, but at the same time still give the individual who intends on interacting with the system the opportunity to still interface with it and be safe while doing so,” Leher says.
Failure to establish and comply with lockout/tagout procedures can lead to some of the worst things that can happen inside a food or beverage plant. A proper safety program can keep things safe while plant personnel keep things moving.