Despite diligent adherence to safety policies and procedures, accidents, near misses and injuries can and will happen during lock out and tag out (LOTO) exercises.
“We have power plants in a lot of different states, and we’ve seen a trend of near misses,” said Kenny Wilkins, site safety manager for NRG Energy, addressing delegates at the Region VI Voluntary Protection Programs’ 2015 Annual Safety and Health Conference, held recently in Corpus Christi, Texas.
Subject matter experts throughout the company, Wilkins said, directed plant personnel to address the incidences to minimize the possibility for disaster.
Accordingly, NRG personnel compiled the LOTO 12 Life Critical Steps (LCS) checklist. Designed to enhance existing LOTO programs, the checklist significantly reduces the possibility of LOTO near misses, injuries and fatalities. According to NRG Energy Training Coordinator Andy Plauche, some near misses occurred because processes were not being followed correctly, but many happened because workers were in a hurry.
Implementing NRG’s 12 Life Critical Steps, he admitted, may slow the LOTO process. “We’ve got to slow it down so we don’t miss any steps,” he said. “We don’t want anybody to get hurt.”
LOTO 12 Life Critical Steps
LCS-1 approves the written clearance request in order to understand the scope of the work to be performed.
LCS-2 develops the clearance, ensuring the equipment-specific isolation procedure is adequate for the protection of all personnel performing work under that LOTO.
“If we don’t know exactly what you’re going to do and how you’re going to do it, we may not get everything you need to be safe,” Plauche explained.
LCS-3 verifies the isolation procedure.
“I’ll look at what needs to be tagged out and locked out for that particular job,” Plauche said. “Then another operator reads the work scope. That’s our first verification in the process. If he suggests we need more tags, we’ll add more.”
LCS-4 identifies hazards and conducts pre-job briefings.
“The operations lead or the shift super-visor fills out a ‘hurt search’ card to identify all the hazards associated with hanging this clearance,” Plauche said. “It might be cloudy, in a dark area or in a slippery area. Whatever the case may be, we’re going to talk about the hazards he thinks I’m going to encounter before I hang the tags.”
LCS-5 isolates the energy sources and hangs tags and locks. The tag hanger ensures isolation points are in the correct position, with the correct tags and locks hung on the corresponding isolation points.
LCS-6 performs independent verification walk-down.
“Another operator looks at every tag and every lock,” Plauche said. “When he’s done, we’ll lock the main lock box.”
LCS-7 verifies the isolation of energy source, either visually or by testing.
LCS-8 specifies the clearance holder (the individual who accepts the LOTO) verifies, by walk-down, the isolation of energy sources provides adequate protection for the performance of the work.
“When he’s done, he puts his lock and tag on the main lock box,” Plauche added.
LCS-9 instructs the operations lead to ensure all clearance holders have signed off and removed locks when their specific portion of the work is complete, their affected personnel are clear, the area is free of hazards and the condition of the equipment has been communicated.
LCS-10 identifies hazards and conducts pre-job briefing or “hurt search” as described in LCS-4.
LCS-11 instructs the tag remover removes the tags and locks.
LCS-12 verifies the independent verifier has removed all tags and locks and equipment is ready for service.
“I’m not saying this is a cure-all,” Wilkins said of the LCS checklist. “But it’s been very successful for us.”
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