Case Study 4: Multiple Energy Control Procedures

A manufacturing facility has 130 separate lockout procedures. Many of these procedures are unique, and apply to specific pieces of equipment. Some of these procedures, however, are duplicate and address pieces of equipment that are essentially identical to another piece of equipment. The facility has 40 employees authorized to implement the 130 procedures in performing service and maintenance covered by the Lockout/Tagout standard.

The employer has implemented the following procedure for conducting periodic inspections: for the specific energy control procedures, each of the authorized employees is observed by another authorized employee performing a complete lockout of at least one piece of equipment or machinery utilizing each one of the separate energy control procedures. The employer documents each of these inspections. However, there are more specific procedures than there are authorized employees, so consequently some of the specific procedures are not observed being implemented. Instead, these procedures are inspected by holding meetings with small groups of authorized employees responsible for service and maintenance on machines or equipment covered by the procedures being reviewed. At these meetings, the relevant procedures are reviewed by the group to ensure that they are understood and effective, but actual lockout implementation is not required during the inspection.

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