Safe, Efficient, Profitable: A Worker Safety Podcast

Paper to Production: Why "Compliant" LOTO Fails In The Field

• Episode 80

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This month we’re tackling one of the most cited OSHA topics out there — Lockout/Tagout (LOTO). If your company has a program that checks all of the audit boxes, but your employees are still having injuries, this episode explains why.

⚙️ Top 3 LOTO Problems We’re Seeing in the Field

1️⃣ Bad or outdated templates.
If your LOTO template or format is wrong, every single lockout procedure built from it can have problems. 

2️⃣ Verification is clear as mud
“Verify” doesn’t mean much if no one knows how, where, or who does it. Joint verification? Remote lockout? Elevated disconnects? If your verification step creates more hazards, your program gaps.

3️⃣ Confusion about when LOTO actually applies.
Some equipment can fall into gray zones where employees “sort of” lock out or skip steps altogether. That’s how culture gaps start. Its important to align  your training, your task steps, and your documentation, with a focus on risk reduction, not perceived "faster" ways.

💡 Bonus : Validate Procedures During Retraining

Your annual lockout/tagout retraining is one of the best times to validate your procedures. Walk the floor with your maintenance team, observe how employees actually perform the work, and capture those missed hazards like residual pressure, gravity, or access height risks.

🧰 Why It Matters

You can have a binder full of lockout procedures and still have injuries.
 A strong LOTO program isn’t just compliance — it has to be customized for your facility.  

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📈 Keywords for SEO

Lockout Tagout Safety, LOTO Training, OSHA Compliance, Machine Guarding, Energy Isolation, Verification Step, Safety Culture, Manufacturing Safety, Industrial Safety, Food Plant Safety, Safety Leadership, Maintenance Safety, Allen Safety, Safety Program Audit, Hazard Control, Employee Safety, Safety Podcast, Allen Safety Coaching, Confined Space Safety, OSHA 1910.147

🔖 Hashtags

#LockoutTagout #LOTO #SafetyTraining #WorkplaceSafety #AllenSafety #SafetyCulture #OSHACompliance #IndustrialSafety #ManufacturingSafety #SafetyPodcast #EnergyIsolation #HazardControl



This video is intended for educational purposes.  Solutions offered are not designed to take the place of an attorney or medical professional, and should not be taken as legal or medical advice.  It is recommended that viewers consult a safety consultant, medical provider or an occupational safety legal team as applicable to help navigate their specific circumstances.  

For educational purposes, videos may show the inside of manufacturing facilities, including meat and poultry production facilities, commercial farming, feed milling, and petrochemical facilities.  Images shown may depict individual lines and show trained employees working in their daily jobs, however these visuals may not be suitable for all audiences.  Specific job tasks shown are being completed by trained professionals, and should not be attempted without proper training and equipment under the supervision of a professional.  Viewer discretion is advised.

SPEAKER_00:

Welcome back to the channel. This month we're going to be covering lockout tag out. It's one of the most frequently cited subjects. We've done a couple of episodes on machine guarding in the past, but it's been a minute. It's been a while. It's been a minute since we've talked about lockout. So we just figured, you know what? We will give you our top three things in regards to lockout that we're seeing right now. Um, so here we go.

SPEAKER_01:

Welcome back, everybody.

SPEAKER_00:

Welcome back, happy tag out.

SPEAKER_01:

What is this? Halloween?

SPEAKER_00:

Happy October. We're in the Burr months.

SPEAKER_01:

Oh, there we go.

SPEAKER_00:

Happy, happy October, happy fall. So that's my orange.

SPEAKER_01:

Anyway, back to lockout tag. So procedures. We're out of here. That's the one everybody wants to know. Okay. I need a lockout procedure for a piece of equipment. I come to you, I say, hey, um, I need one. You're gonna go to share drive and whatever.

SPEAKER_00:

I'm gonna hope that we have one. And inevitably, when I pull it up, we either A, don't have it. Which is weird. Because we we have a master inventory and we have one for everything except inevitably the one that you need right now.

SPEAKER_01:

Especially if it's an audit. If it's an audit, it's the exact one.

SPEAKER_00:

We're probably in the yeah, we're probably in an audit. And then it's gonna be on some weird, really dated template. Then I'm like, where did this even come from? We moved all of this stuff over six months ago forever to this new format that's so much better. Like, where why does it look like this? And that's usually the cycle that starts. Now I'm not saying that that happens every time, I'm just saying we've we've experienced that firsthand, that cycle many times.

SPEAKER_01:

So that's the start of your top three. So there you go. The procedure itself.

SPEAKER_00:

Yeah, is it the template?

SPEAKER_01:

The template, yes.

SPEAKER_00:

What is on it? Because this is one of those subjects that if the template's wrong, your 300 lockout procedures are irrelevant to a certain degree on that specific subject. Then they're completely like it's the multiplier is so huge, that's gotta be right. The template's gonna be right. Yes, we do.

SPEAKER_01:

So it has to be correct.

SPEAKER_00:

I'm sorry, I'm having a tickle.

SPEAKER_01:

Yeah, so if the format right there with that new cup, like what's going on there?

SPEAKER_00:

All right, so um brief interlude, brief interlude. Um, part of what I've been spending my time doing is safety merch is dull and it's boring. And uh we wanted some fun stuff to wear. Because we don't have any sponsors. We don't have any sponsors. We wanted some fun stuff to wear, fun stuff to have. So I've got the new Allen Safety Hazmat team steampunk cup. Um, we've got shower curtains, we've got rugs, we've got like entryway rugs for your front door, we've got the big handled thermos cups, we have snow gloves. We've got snow gloves, we have toddler t-shirts and onesies, we have canvas, um, like dog material, embroidered vests. We have all these things. So um they're fun. They've got a little pizzazz, a little personality. You can find them on our Amazon store, Allen Safety LLC's Amazon store, or um, we've got an even larger uh variety of merchandise over at the Allen Dash Safety.com page under merchandise. So check it out. Something kind of fun. There you go.

SPEAKER_01:

All right, back to logout. So now we have the procedure, the formatting, and then it's gonna say things on there like verify. Yep, and that is number two.

SPEAKER_00:

With what?

SPEAKER_01:

Right, so you're using the procedure, and now it ties in number two because the verify itself could be unlimited choices because uh one procedure it may be remote, another procedure it may be two or three pieces. That one line item can just take off on you.

SPEAKER_00:

My brain's going in like 15 different directions because it feels like because there's so there's so many variations of the word verify that we've seen, and it's kind of like oh okay, it'll just say the word verify, and you're like, who? How doing what? Where? How many people? Because there's this thing floating around that's called joint verification, and that's a thing for some locations, and they are okay with that, and some are not.

SPEAKER_01:

Verify could be the disconnect is 10 feet up air, but the verify is somewhere completely different. So now you make them do elevator work as a hand.

SPEAKER_00:

Or there's no way, really, or yeah, or there's no way there's no computer system, you can't do that. There's no yeah, there's no safe way. The verification puts them at more risk than we really want them to, and so they don't feel comfortable doing that process, so they just don't verify. And arguably, verify and verification is the most critical part of lockout because there's always I am new, stuff was mislabeled, I was tired of putting on the weekend, put it on the wrong, you know, disconnect, wrong, right, wrong ball valve. I mean, there's all these things, or there's just residual and we didn't bleed out the lines.

SPEAKER_01:

I mean, that we've seen airlines 30 feet long, and people say, Oh, it takes like two seconds, you stand there, it takes it goes forever.

SPEAKER_00:

You're just standing there waiting and waiting. They never did it for that length of time. They're like, Shh, got it, and then we move on.

SPEAKER_01:

Absolutely. So you gotta look at your so you've got the lockout, the procedure that could be a hazard.

SPEAKER_00:

Yep.

SPEAKER_01:

Then you got I gotta verify, which now that could be a hazard. And now I go back to now I'm who says it's even right. So it could be the person that signed it, verified whatever, may not even know if it's right or not.

SPEAKER_00:

It it's it goes back to who's writing it, right? So we have, and this is this is not a plug, it's just a reality. We have a app that I developed with the help of some IT people that we created to speed up the process of writing lockout procedures, and because we were able to accomplish that, we were able to cut the time it to almost a third of what it would take. And so and they're picture driven, they're amazing. And we had several companies approach us that wanted to either have a subscription to this or like have some kind of service or buy it, and I won't do it. And the reason why I won't sell it because that's because it matters who's doing it, if they do it and write the the procedure, but it's wrong, it still doesn't matter. They don't understand the procedure, they don't understand the equipment, they don't know the mechanics, who cares? So in our company's still wrong.

SPEAKER_01:

So in our company, we even select who goes to that location to write those like our procedures.

SPEAKER_00:

Based on who's the expert. I've got a cattle expert, a case ready expert, mill expert. Yep. We have someone that covers all of those things that understands the mechanics of the equipment and also the weird stuff, and then when where they can like override stuff, they know all of those weird things, and so we do select that and then we still validate with the people and work with them maintenance for that area, yeah, uh, wastewater for that area, wherever their department experts are.

SPEAKER_01:

Because, like, for example, we we worked with the manufacturer, built some of the robots for years. Yeah, and as we did that, we would come back and they would say, Oh, lockout, tag out, you do this. But we know there was more to it. If you don't have that knowledge, and or if you don't ask that maintenance person sets up the equipment, finds out you don't always lock it out the way during the setup, do you have to use air to set it up? Oh, you can have confusing parts of the lockout procedure.

SPEAKER_00:

Yeah, so that is really part of the deal, too, is is it's not always the safety person that is writing or reviewing these. Now they're a stakeholder for sure. They need to make sure that the right components are in the template. Right. But they may not always know sanitation has to do XYZ or maintenance to troubleshoot this equipment, to unjam it during production with film, to do things like setup. We have to sometimes have power to certain things, and we use other means of guarding by things like distance, but we still have to have power to some of it. And so we have different safety things that we put into place. But if they're not there to see that, or they don't know that room, that department, that equipment, or they haven't been at the location that long, that's getting missed. And that's where we're seeing some of these injuries still because it's not being captured in the procedure that we're training everyone on and saying follow this, but then no one's following it because well, what we do is really safer, but it's never been captured. And so now there's this weird thing of we don't follow the procedure. Well, now that's weird culturally, you know, from a safety culture standpoint of like sometimes we follow the procedure and sometimes we just flat out ignore it, you know. Like that's so it gets really weird.

SPEAKER_01:

And then you also get um probably my my last one is when does it apply when yeah you take a you take a dump and you got guards inside of it, yep. So so the cable that runs in front of it.

SPEAKER_00:

So just I'll throw up a picture, but a combo dump or so lifts and then dumps into a blender.

SPEAKER_01:

There's so many variations when you have to lock that out, yeah, because they haven't decided when you break the plane.

SPEAKER_00:

Yeah, what is the plane and what's the guarding look like on the outside? Are we still doing a chain or have we beefed it up a little bit?

SPEAKER_01:

You'll get different pieces of equipment. People say, Oh, I didn't really break the plane, or I don't have to lock it out for that task, or I'm only taking a sample, and you're like, we use a tool so we never do, or we never use a tool and we go in with our whole body. Yeah, there's all of that is part of the process.

SPEAKER_00:

Yeah, so part of it is breaking it down by the employee behavior. So some of that can obviously be changed by training and then managing the behavior from then out after that training happens. So it's a culture issue, right? Yep, we've got the the verification piece of how, when, where, who, what, joint verification, can we or not? Am I doing it on a radio? Can I actually push the button next to it? Or did I take the PLC computer screen down? Yeah, because do I have to do it in a control room? Well, I'll just cut you right off. Don't worry, I get excited.

SPEAKER_01:

Because the new computer systems won't allow you to lock it out sometimes without the computer being down forever.

SPEAKER_00:

Well, you d here's my theory on this. It's because it costs more money to separate that out and wire it apart from everything else. Like a glue pot. So if we didn't specifically ask for that to be done and understand that's going to be an added cost, that may that probably wasn't done, you know.

SPEAKER_01:

So, and then the final part is that final final. Yeah, that's right.

SPEAKER_00:

Is this the bonus?

SPEAKER_01:

I guess call it bonus, is that during the year when you retrain your employees and you're validating lockout tag out, that is the best time to validate the lockout tag out procedure. 100%. Because if you're going through it, it's line four, and you're like, that's weird, we don't do it there. That's when you got to capture that data. If you don't, if you're kind of like, oh, I got my employee trained, and you don't really push that number four was off, you can cycle the next person, an expert, and you miss it.

SPEAKER_00:

But only, only caveat to that is if you have someone who's an expert that at that department, right training on equipment that's in that department, right? That's not a single source conveyor.

SPEAKER_01:

Right. So theoretically, you don't want to train on the least items of disconnect the person's working on.

SPEAKER_00:

And everyone gets trained on the same item.

SPEAKER_01:

Everybody gets trained on conveyor number three in the front office. No, what you want is you're you do a task, you have five things you have to lock out, and that's the worst one you have during the air, you that's the one you should be trained on.

SPEAKER_00:

Yeah.

SPEAKER_01:

Because you need to understand the hydraulic, the pneumatics, and how everything, gravity, how everything's gonna work for that. You take a mixer blender and lift up the lid. If you don't lift it up a certain way and put the pin in a certain way, you have to worry about the lid coming down.

SPEAKER_00:

So it's it's yeah, well, and it's under it's understanding that the lid closes and you have to even have that included in that. I mean, like most people just don't have that in their understanding.

SPEAKER_01:

It doesn't talk about you're talking about the elevator, it don't even talk about how far you have to climb a ladder to lock something up. That's a risk. In closing, you want to look at your procedure, take it out there during the different times, basically, see how they do the task, and then look for those random safety risks that are created because of the procedure, make sure you capture that as well.

SPEAKER_00:

Different times of day, grab the look the the department expert that really knows, knows how and when we just shove this piece of wood from a pallet or this cardboard from a combo in here. We can override the safety and then like unjam stuff real quick. Yeah. You want those people that have been there for a minute and know what's going on. So, yes, this is a safety function. Yes, it feels as the safety person very overwhelming sometimes to realize hey, I've got 300 lockout procedures.

SPEAKER_01:

And they take about 30 minutes or more each to write them from scratch.

SPEAKER_00:

But also, if you're going to go out and physically validate, that takes time. That takes forever. But also, most safety people aren't mechanics. So that's why I want to encourage you grab a mechanic with you. Um, great, great cross-training option right there. I mean, great continued education that's a hundred percent relevant. You didn't have to go anywhere or leave and and you're getting an awesome education, it's gonna better you as a safety person. But also you have confidence that it's correct. So it's not we have a sheet of paper and they still got hurt because that's what we see a lot. We have we have the procedure and they still got hurt. So yeah, that's it. That's our opinion. Take it how you want. Take what you can from this. And if it was helpful or beneficial at all to you, please like, share, all of the things. Um, this is a community service for Joe and I doing this. Um, the only intent that we have in doing these is we want to get them to those who need them. Um, those who maybe don't have the information. We recognize there are a lot of people that are walking into safety that maybe don't have formalized training in it. So let's get these podcasts and these YouTube episodes out to them and um help us make a difference. That's all we're asking. And again, if you want to contribute, Alan Safety.com's merchandise page, you can get you a snow globe. You can get a shower, you can have entire Allen Safety bathroom decor from our stuff. So anyway, um, have a safe week, everybody. Take care, and we will see you next time. Thank you for listening to Safe Efficient Profitable, a worker safety podcast. If you're looking for more in-depth discussions or step-by-step solutions on all of the different safety and regulatory topics, please visit us at www.alensafetycoaching.com for web-based virtual coaching and training, or at www.allen-safety.com to book our team for on-site services, training sessions, to order merchandise, to learn more about our team and what services we provide in the field, or discipline or requested topics for us to cover on our next podcast. If you have today's podcast, help you like to support our podcast further. Please help us by subscribing, liking, and sharing this podcast. Anyone that can benefit from the information we cover here is.

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Joe Allen

Host
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Jen Allen

Co-host