“I just found out that one of your supervisors cut off a lock that had been used to deenergize a hazardous machine even though he wasn’t the person who applied the lock,” said Tammy, the compliance officer.
“Yeah, I know we had some communication problems during a shift change,” said George, the supervisor. “So the lock was still on the machine even though the person who affixed it had left for the day.”
“That’s a violation of our lockout/tagout regulation, which mandates that the only person who can remove a lock is the same one who put it on to begin with,” said Tammy. “I’m writing up a citation.”
“You’re a real stickler,” said George. “We had to get the machine up and running for the second shift, and we were unable to reach the guy on the first shift who put on the lock. He should’ve told his boss about the lock before he left for the day, but he didn’t. So the supervisor for the second shift had to cut off the lock so we could use the equipment.”
“The lock had to be removed by the person who put it on,” said Tammy.
“Your regulation also requires that locks be affixed before anyone services a machine,” said George. “In this case, no one serviced the machine. We just operated it for the rest of the second shift.”
“Now you’re the one who’s being a stickler,” said Tammy.
“No one was exposed to an equipment hazard,” said George. “We’ll fight your fine.”
Did the employer win?
Yes. The employer won. The Occupational Safety and Health Administration Review Commission overturned the citation.
The commission said the lockout/tagout regulation didn’t apply in this case because no one serviced the equipment after the lock had been removed. As a result, there was no violation of the rule, which mandates that locks be removed by the same person who put them on prior to machine servicing.
While the employer could’ve done a better job of communicating from one shift to another, the commission noted that no one was actually exposed to a hazard because of the mix-up over the lock.
What it means: Don’t neglect the next shift
Pay attention to effective communication during shift changes. When workers on one shift do something that could affect those on the next shift, there’s a need for adequate communication between the two shifts. In this case, the worker who applied the lock on the first shift failed to alert those on the second shift.
What to do: Periodically let staffers know about the value of effective intrashift communications. After all, they’d be upset if someone suffered an injury on their shift because employees on the previous shift failed to relay important safety information to them.
Based on Secretary of Labor v. USPS Portland Processing Center.
(From the June 3, 2024, issue of Safety Alert for Supervisors. To start your no-obligation trial subscription to the publication right now, please click here.)