FOOD MANUFACTURING ROOT CAUSE ANALYSIS Lockout/Tag Out TECHNICAL PAPER PAGE | 18
APPENDIX 2
CONTROLS/SOLUTIONS FOR TOP PRIMARY CAUSAL FACTORS
k) Have contractors provide their workplans, including LOTO of equipment, prior to starting work,
and monitor and enforce conformance.
l) Have a LOTO "log sheet" for each piece of equipment.
m) Ensure LOTO is part of pre-task communication and hold employees accountable for
meeting expectations.
n) Build LOTO monitoring into existing evaluations and inspection methods used (e.g.,
supervisor inspections).
o) Encourage minimum (evaluated) standards for supply chains.
p) Incentivize OHS related equipment purchases, such as LOTO devices.
q) Conduct MLITSD blitz on Lock out/tag out.
r) Empower HSAs to do more legal compliance type inspection/site visits.
7.2 Category: Tools & Machines
Primary Causal Factor: Inadequate LOTO Devices
a) Implement LOTO stations that are easily accessible.
b) Ensure LOTO program includes a procedure for reporting cut or missing locks/devices.
c) Implement LOTO log sheets.
d) Require any employee who must lock out as part of their job to have their own company issued
locks with 1 key - no duplicates. (Eliminate chance of another being able to open the lock. If the key
is lost, the lock must be cut off.)
e) Have the name and picture of the employee on their lock(s).
f) As part of the procedure the employee must always carry at least one lock and hasp with them.
g) Ensure that each person working on the equipment has their own lock attached to the device
(or locked box in the case of a group lockout).
h) Ensure that each department has its own colour lock (production red, maintenance blue, temps.
orange etc.)
i) Have a central area for extra hasps and other LOTO devices (plugs, valves, butterflies, etc.) for
easy access.
j) Have a hard copy on file of who has the locks so the locks can be reissued as needed (for new
employees/existing employees on leave, etc.).
k) Incorporate all the above controls/solutions into the LOTO procedure and possibly into the
Regs/Standards (e.g., CSA).
l) Have a centralized location for all devices.
m) Keep back up supply of devices.
n) Keep often used devices in convenient locations by the machine.
o) Subsidize cost of devices for smaller companies.
p) Educate on devices and their uses.
q) Consider different technology, such as trap keys, interlocks, photo eyes, etc. (caution: technologies
such as interlock do not replace the need to lockout).