FOOD MANUFACTURING ROOT CAUSE ANALYSIS Lockout/Tag Out TECHNICAL PAPER PAGE | 14
APPENDIX 2
CONTROLS/SOLUTIONS FOR TOP PRIMARY CAUSAL FACTORS
2. Category: Processes
Primary Causal Factor: Lack of Procedure (Program)
a) Prescribe legislative requirement for a LOTO program (like confined space and violence).
Include minimum standard for program requirements.
b) Create standardized training provisions for LOTO.
c) Provide guidelines and resources (including templates), in plain language, for the development of
LOTO programs and procedures.
d) Establish provisions (or trigger) for providing OHS information/resources (e.g., LOTO requirements)
for new businesses, such as when they register for a license, or WSIB account. *
e) Expand Control of Hazards topic in HSEp to include a list of specific control programs (such as LOTO).
f) Provide Safety Connection events highlighting LOTO.
g) Develop mentorship programs.
h) Conduct study detailing trends in causal/contributing factors related to LOTO incidents.
i) Make decisions related to LOTO prosecutions more readily available.
j) Publicize MLITSD Safety Alerts.
k) Conduct MLITSD blitzes on LOTO
l) Produce HSA initiatives on LOTO (such as media communications).
3. Category: Processes
Primary Causal Factor: Inadequate training
a) Where feasible, have a dedicated, competent internal trainer on site.
b) Have a train-the-trainer program.
c) Audit/verify the competency of the trainers.
d) Ensure that training:
a. Is based on a recognized standard (such as CSA Z460, CSA Z462)
b. Includes both theory and practical components
c. Includes generic and equipment specific procedures
d. Considers the language of the participants (ESL)
e. Includes multiple visual elements
f. Is provided in a quiet, comfortable, safe environment (for effective learning)
g. Includes verification of knowledge and behaviour.
e) Where reasonable, equipment specific training should be designed with a layered approach (tiered
system of training based on the difficulty of LOTO).
f) Provide Instructions for all affected staff, not just employees authorized to perform LOTO.