FOOD MANUFACTURING ROOT CAUSE ANALYSIS Lockout/Tag Out TECHNICAL PAPER PAGE | 17
APPENDIX 2
CONTROLS/SOLUTIONS FOR TOP PRIMARY CAUSAL FACTORS
h) Demand strict enforcement of LOTO requirements.
i) Establish audit system of monitoring/enforcement, and LOTO performance.
j) Ensure adequate distribution of locks and other LOTO devices.
k) Clearly identify tasks requiring LOTO.
l) Identify all positions and circumstances that may be exposed to hazardous energy.
m) Implement a permit system for "live work" that includes:
a. Clear statement as to why live work is necessary
b. Risk assessment
c. Written instructions
d. Senior management sign off.
n) Conduct "fit-for-duty" assessments (fatigue, personal issues, mental health) by worker or supervisor.
o) Create awareness campaigns related to "fit-for-duty".
p) Develop training for workers/supervisors on signs and symptoms of "unfit for duty".
q) Where required, include LOTO requirements in pre-shift meetings.
r) Ensure recruitment includes OHS (e.g., LOTO) related questions.
s) Conduct regular awareness campaigns related to LOTO.
7.1 Category: Processes
Primary Causal Factor: Inadequate Monitoring and Enforcement
a) Clearly state (including zero tolerance) disciplinary measures for LOTO related infractions.
b) Train/instruct supervisors and senior management on monitoring and enforcement requirements.
c) Create OHS metrics for supervisory monitoring (such as BBS observations) and enforcement:
Consider the following:
a. Give feedback on positive and negative actions
b. Hold supervisors accountable for adhering to the metrics (performance monitoring)
c. Share metrics with all supervisors (may invoke competition between shifts, teams, etc.)
d. Include senior managers
e. Showcase/spotlight high hazard programs like LOTO on a rotational (more frequent basis)
d) Incentivize positive OHS metrics, leading indicators (e.g., free lunch for stop, assess, control BBS).
e) Include monitoring and enforcement responsibilities in supervisor job descriptions.
f) Consider a sensor on LOTO points (indicates if a lock has been applied).
g) Consider installation of alarms on equipment to alert when LOTO devices are removed.
h) Ensure the LOTO program includes provisions for monitoring and enforcement (evaluation).
i) Tie coaching/corrective actions to enforcement.
j) Have workers also monitor and encourage safe LOTO practices.
