CVE Certified SDVO and 8(a) Corporation. To contact Editor of this issue Over $30m in services provided since 2007

Experience Can Breed Complacency

Every time I update my classroom training materials, I am amazed at some of the statistics.

According to the Bureau of Labor and Statistics(2012), “The final count of fatal work injuries in the U.S. in 2010 was 4,690.”

This means that an average of 13 people don’t come home from work each day. The statistics also show that the majority of fatalities are among white males between the ages of 45-54 years old and close to 5% of that is death or injuries due to lack of Lockout and Tagout compliance required by OSHA in 29 CFR 1910.147(a)(1) & 174(b).

This “experience” leads many to believe that with over 10 years of experience, these people have become lax about safety and take greater risks while at work.

We can’t tell you how many times it happened in the industry where someone says “I have done this hundreds of times before” and then get injured on the job because they cut corners, or lack machine-specific knowledge or instructions.

Managers often have the difficult job of policing this type of behavior. Of course, the best prevention is to comply with OSHA. When “Safety First” is a way of life, people learn to look out for each other and comply with the law.

Joint Commission and OSHA Lockout/Tagout Compliance

Through numerous conversations with facility managers, inspectors, and consultants we have found three basic areas that the Joint Commission and OSHA look at when it comes to Lockout/Tagout.

First, they look for machine specificprocedures. OSHA (1999) states:
“The use of generic energy control procedures alone are unacceptable, since generic procedures do not meet the provisions set forth in 1910.147(c)(4)(ii). OSHA believes that a specific and documented procedure is necessary for most energy control situations because of the number of variables involved in controlling hazardous energy and the need for authorized employees to carefully follow the sequential steps in the energy control policy."

The second area of concern is annual training. 29 CFR 1910.147 (c) (7) covers the employers responsibility for training authorized employees, maintaining lockout/tagout training records.

Third, OSHA and the Joint Commission are concerned about Annual policy reviews.

We all know that most facilities have construction or remodeling going on constantly. Without having a policy in place to catch these changes, and update policies and procedures, many facilities find that their own lockout/tagout procedures and policies have become obsolete.

Workplace Violence is Becoming a Greater Problem

As we have seen in recent weeks, violence can happen anywhere and at any time.

The Bureau of Labor and Statistics (2012) show there were 270 workplace suicides and 518 workplace homicides in 2010.
The statistics show a shift from robbery-related homicides to more cases caused by domestic dispute.In 2010, the majority of workplace homicides were committed by close friends or relatives, primarily current or former spouses.

The Texas Department of Insurance has a 2 page fact sheet with some great information. Click: The annual injuries and deaths related to Logout and Tagout can be found in

Continued Lockout/Tagout Compliance

After reading the article on compliance, if you feel your program is in need of review or a complete overhaul, give us a call for a no obligation consultation.

With both in house and industry partnerships, we can assist you in design, creation, and implementation of a Graphical Lockout/Tagout program and machine specific procedures. We also provide annual classroom training and procedure review.

About Our Organization…

Kepa Services Inc. (KEPA) is a Service Disabled Veteran Owned (SDVO) and 8(a) certified Company.

As a Professional Construction Management Services Firm, we specialize in General Contracting, Design-Build Construction for government and commercial projects as well as safety compliance, and energy reduction services.

KEPA's owners and management staff have, on average, over ten years of experience in multi-million dollar project management for most federal, state, and local government entities, as well as larger commercial clients such as Blue Cross/Blue Shield, GE,and Siemens.

Kepa has also started a mentor-protégé with TCI, a government facility design, engineering and contracting firm. Kepa also has a partnership with Grainger, a GSA schedule approved LED fixture provider. With strong partners, we can provide one stop solutions for your energy needs.

Example of Logout

During facility audits we are finding that most facilities are not compliant in the areas of Lockout-Tagout and Confined Space policies. There are 4 major areas of non-compliance:

1. Facility does not have a comprehensive and clear Lockout-Tagout policy.
2. Facility does not have machine specific procedures for all equipment with one or more energy sources.
3. Authorized and Effective employees are not trained or retrained on an annual basis.
4. Annual reviews of training, policies, and procedures has not been completed or documented.

If you are not certain if your policies and procedures are compliant, call 920-254-7062 for a free phone consultation or an onsite evaluation. Kepa Services Inc. is your safety compliance partner.

  Kepa Services Inc.
  2300 N. Mayfair Road, Suite 100,
  Milwaukee, WI  53226

  Tel: (414) 476-2600 (Office)
  Fax: (414) 476-2610
  Fax2: (262) 922-9908 (Internet)


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