A food safety incident can severely damage a company's reputation and erode consumer trust. Therefore, maintaining safe working conditions in the food processing industry is essential, especially given the complex machinery and equipment employees interact with daily. A critical safety protocol is the lockout tagout procedure, designed to safeguard workers from hazardous energy releases during maintenance or servicing tasks.
Lockout/Tagout Violations in Food Processing Industry
From 2019 to 2022, the average number of fatalities from being in contact with objects and equipment is 723 per year. These are accidents caused by being:
- Struck by object or equipment
- Caught in or compressed by equipment or objects
- Struck, caught, or crushed in collapsing structure, equipment, or material
Even though transportation-related incidents were the leading cause of occupational fatalities in 2022, accounting for 2,066 deaths, equipment/object-contact incidents ranked fifth with 738 fatalities (US Bureau of Labor Statistics, 2022). One common cause of such fatalities is the unexpected startup of machinery during servicing or maintenance, highlighting the importance of properly implemented lockout/tagout procedures.
The Bureau of Labor Statistics identifies the food manufacturing industry as one of the most hazardous sectors. Over the past two decades, the Occupational Safety and Health Administration (OSHA) has imposed significant penalties on violators within this industry.
Several prominent food industry companies have been penalized for LOTO violations. In one incident at a food manufacturing company, a 39-year-old production worker's left arm was caught in a running auger, resulting in partial amputation and multiple lacerations.
OSHA's investigation in September 2020 revealed that the company failed to train its workers on lockout tagout procedures during maintenance activities. This same company has already committed the same violations back in 2016. Consequently, the proposed penalties amounted to $136,532.
If your workplace does not yet have LOTO procedures in place, would you wait for an accident to happen or for OSHA to inspect your facility, whichever comes first?
LOTO Safety in the Food Processing Industry
Much like with other industries, machines used in the food processing industry must be de-energized and their energy sources secured before servicing. Employers must ensure that workers are trained to implement safety procedures to prevent a machine from unexpectedly starting up during servicing and maintenance. And that only the trained, authorized employees perform maintenance or service on machinery.
Implementing lockout tagout procedures in the food industry presents unique challenges. The environment demands high levels of hygiene and cleanliness, which can complicate the implementation of energy isolating devices.
The need for continuous production of food products to meet consumer demands means that equipment is often in constant use, making it difficult to schedule maintenance without disrupting operations. Additionally, the presence of wet conditions, extreme temperatures, and the use of chemicals for sanitation can all impact the effectiveness and durability of LOTO devices.
Examples of Hazardous Equipment in the Industry
The food processing industry uses a variety of complex and potentially hazardous equipment. Examples include:
- Mixers and Blenders: These machines can cause severe injuries if they start unexpectedly during maintenance.
- Slicers and Dicers: High-speed blades pose significant risks, making LOTO procedures essential to prevent accidental startups.
- Conveyors: These systems can lead to entanglement injuries if not properly locked out.
- Packaging Machines: Often automated and complex, these machines can cause crush injuries or amputations.
Part of a successful lockout tagout program involves clear visual indicators that can help workers identify secured energy sources. All employees in your maintenance team should have color-coded sets of locks with matching keys. Color coding can help workers retrieve their locks and identify which teams are currently servicing a piece of equipment. TRADESAFE Safety Padlocks come in eight color choices: red, blue, green, orange, purple, yellow, white, and black.
Depending on what your workplace needs, these padlocks can be keyed alike or keyed differently. Moreover, TRADESAFE offers specific lockout devices for circuit breakers, gate valves, group lockout solutions, and more.
Lockout Tagout Training
Proper training is crucial for the effective implementation of LOTO procedures. In compliance with the OSHA Standard for Lockout Tagout, authorized and affected employees must be trained to recognize hazardous energy sources, understand the importance of LOTO, and know the correct procedures for applying and removing energy isolating devices. Training should be continuous and updated regularly, especially when new equipment or processes are introduced.
Documentation is equally important. It provides a clear reference for employees and ensures consistency in LOTO procedures. Detailed records of training sessions, maintenance schedules, and energy isolating device inspections help in maintaining compliance and identifying areas for improvement. Proper documentation also serves as evidence during OSHA inspections and can mitigate potential fines or penalties.
Free Lockout Tagout Course
Whether or not your company belongs to the food processing industry, you can take advantage of a free LOTO training course offered by the National Grain and Feed Association (NGFA). This course covers LOTO safety procedures that can be adapted to any workplace. It emphasizes the importance of having a comprehensive energy control program, which should include:
- A written program detailing lockout instructions for machines
- Employee training
- Periodic employee inspections
- Periodic inspections of specific machine lockout procedures
For workers to better visualize how they are supposed to do lockout tagout, include illustrated samples in your hazardous energy control procedure. Here are some examples from the NGFA course:
Best Lockout Tagout Practices in the Food Industry
Best practices ensure that all stored energy sources are properly controlled, reducing the risk of accidents and enhancing overall workplace safety. Here are essential LOTO practices to follow in the food manufacturing industry:
Developing a Comprehensive LOTO Program
Creating a thorough LOTO program involves establishing clear, written procedures tailored to each piece of equipment, and outlining specific steps for shutting down, isolating, and securing machinery. This program should be easily accessible to all employees and regularly updated to reflect any changes in equipment or processes. Providing detailed documentation and training ensures that all employees are aware of and can effectively implement LOTO procedures.
Adhering to the OSHA Standard for Control of Hazardous Energy (29 CFR 1910.147) is essential, as it provides the regulatory framework and requirements for effective LOTO practices, helping to minimize risks and ensure compliance.
Conducting Regular Inspections and Audits
Regular inspections and audits are essential to verify that LOTO procedures are being followed correctly and consistently. Inspections should check the proper application of energy isolating devices and adherence to protocols, while audits review the overall effectiveness of the LOTO program through documentation and employee interviews. Immediate corrective actions should be taken to address any deficiencies or non-compliance issues identified during these audits.
Importance of Employee Involvement
Employee involvement in developing and refining LOTO procedures is crucial as it ensures practical insights and increases compliance. Employees who actively participate in the creation of safety protocols are more likely to follow them diligently. Encouraging feedback and suggestions from workers helps to identify potential hazards and improve the effectiveness of LOTO practices.
Using Visual Aids and Tags
Incorporate visual aids such as safety posters, tags, and color-coded locks to make LOTO procedures more understandable and accessible. Clear and consistent visual communication reduces the risk of mistakes and ensures everyone is aware of the LOTO status of machinery.
Collaborating with Safety Experts
Consult with external safety experts or organizations to review and improve your lockout tagout program. Third-party audits can provide an unbiased assessment of your procedures and identify areas for improvement. Stay informed about the latest safety technologies and innovations that can enhance your LOTO program.
Enhanced Training Programs
Go beyond basic training by incorporating advanced topics such as hazard recognition, risk assessment, and emergency response. Utilize a variety of training methods, including e-learning modules, workshops, and simulation exercises, to cater to different learning styles. Regularly update training materials to include the latest industry best practices and regulatory changes.
Using the Right Equipment
Ensure that the appropriate lockout tagout devices are used and that each worker has their own lock to prevent relying on a coworker’s lock. Proper labeling of energy isolating devices such as breaker panels and control valves is essential for clear identification. Providing enough locks, tags, and any other necessary hardware helps ensure that energy control procedures are followed correctly.
Emergency Response Preparedness
Develop and regularly update emergency response plans to address potential incidents involving hazardous energy. Conduct drills and simulations to ensure employees are familiar with emergency procedures and know how to respond effectively. Review and refine emergency plans based on lessons learned from drills and actual incidents.
Addressing Common LOTO Violations
Identifying and addressing common LOTO violations, such as failing to de-energize equipment or bypassing safety protocols, is critical to maintaining a safe work environment. Implementing corrective measures, conducting regular training, and reinforcing the importance of LOTO compliance through continuous education can significantly reduce these violations. Management should ensure that all employees understand the risks associated with non-compliance and the steps necessary to avoid these common pitfalls.
The Impact of LOTO Procedures on Food Safety
Lockout/tagout (LOTO) procedures significantly enhance food safety by ensuring machinery is de-energized and secured during maintenance, preventing accidental startups and hazardous energy releases. This control over equipment reduces injuries and fatalities, fostering a safer work environment. A safe workplace not only helps protect workers but also prevents interruptions in production that can lead to contamination of raw ingredients and compromise the shelf life of the final products.
Implementing lockout tagout procedures prevents product contamination by ensuring equipment is cleaned and maintained in a de-energized state, eliminating the risk of accidental startups that could spread contaminants. Consistent adherence to general industry standards and regulatory requirements helps maintain the integrity of the food produced. Additionally, LOTO protects equipment integrity by preventing wear and tear, extending equipment lifespan, and maintaining efficiency and reliability, which contributes to consistent production quality and safety.
FAQs about Lockout Tagout in Food Manufacturing
What is the main purpose of lockout tagout?
The main purpose of lockout/tagout is to protect workers from hazardous energy releases by ensuring machinery is properly de-energized and secured during maintenance.
What is lockout in manufacturing?
Lockout in manufacturing involves isolating and securing energy sources on machinery to prevent accidental startups and ensure safe maintenance.
What is a proper practice for a lockout tagout situation?
A proper practice for a lockout/tagout situation includes identifying all energy sources, isolating them, and applying lockout tagout devices to prevent accidental machine operation.
What situations should I use lockout tagout?
Lockout/tagout should be used during any servicing, maintenance, or repair work on machinery where unexpected energization could cause harm.
Why is it important to always perform lockout tagout procedures?
Performing lockout/tagout procedures is crucial to ensure worker safety, prevent injuries, and avoid equipment damage during maintenance activities.