Contain your energy: How to develop an energy control program

Every day, workers are exposed to a variety of hazards from equipment, industrial machines and processes. Although each worker is responsible to ensure he or she follows safety procedures at all times, companies are still obligated to ensure energy control procedures are in place and in compliance to applicable standards.

Companies are responsible for developing procedures to ensure a zero energy state and prevent inadvertent start-up of equipment, machines or processes to protect workers. Every company using equipment, industrial machines and processes that could potentially expose workers to hazards should have an energy control policy or similar plan in place that describes all safety procedures for each job function. This policy must be made available to new workers during orientation, and must explain all safety procedure types, including when and how to use them. The policy should describe all company and worker requirements, and include the frequency of worker retraining or skills demonstration.

Depending on the type of manufacturing environment, the energy control policy may need to describe methods of energy control that go far beyond the traditional lockout method, keeping in mind that lockout is not the only method of energy control. When special circumstances exist, you can use other methods in accordance with CSA’s Z460 standard, making matters more complicated for energy control policy developers.

In spite of all the efforts made by companies to implement energy control programs, we continue to hear about workplace accidents regularly, begging the question why?  In my opinion, there is a great deal of misunderstanding when it comes to energy control policies. Workers don’t understand the difference between an energy control policy, a safety device and a safety procedure. Recently, a worker was arguing with me during class. Why do we need safety procedures when safety switches are installed to protect us? But safety protection devices and a procedure on how to perform a task safely are two different things.

Yes, we need safety protection devices to ensure energy is interrupted under certain operating conditions, but hazards are all around workers when multiple energy sources are present. The only way to ensure a task is performed safely is to follow the steps outlined in a safety procedure after all risks have been assessed.

In my opinion, the most common causes of work-related accidents are: human error, outdated safety procedures and/or lack of training and improper risk assessments.

• Human error: Some workers continue to believe that just because they have performed a task several times, they have memorized the steps and are convinced they could perform the task safely every time. This is definitely a fallacy, and the cause of numerous workplace injuries. During one of my classes, I had an individual tell me that “if I can’t perform this task without the piece of paper, then I should not be called a tradesman and definitely should not be here doing what I’m doing.” I was very sympathetic with the individual and knew where he was coming from; still, I stressed, once again, the reason for writing procedures is so that we read them every time we perform a task to ensure the task is performed consistently, without forgetting a step, to minimize risks. By not following written procedures, we accept higher risk, which may lead to worker injury.

• Outdated safety procedures: Safety procedures must be maintained and current at all times. Safety procedures should be reviewed when equipment, machines or process modifications are made, because workers rely on safety procedures to gain safe access to equipment, machines or processes. Making modifications on interlocks, operation and/or safety devices demands a complete review of all relevant safety procedures and a PSR to be conducted, to ensure risk assessment is complete and all energy sources are isolated or controlled. It is also very important to train and/or re-train workers on how to use safety procedures. It is wise to involve workers from different departments during the assessment, escalating the importance of safety, creating meaningful dialogue and raising the awareness level.
 
• Improper risk assessments: Safety procedures in general must be developed by qualified people and must always be based on the results of a risk assessment. Conducting a risk assessment plays a key role in any safety procedure implementation in that it identifies all energy sources, hazards and equipment/process interactions or interlocks that may cause inadvertent start-up of equipment. The result of a risk assessment identifies all hazards and the steps required to eliminate them, which may include specific controlled actions by the worker. I witnessed one situation where the worker performed a task, inside the hazardous envelope, without a written procedure and all energy sources present. Someone had told the worker it was okay to do this on the machine when no one was looking. I believe you can figure out on your own how much risk the worker accepts by performing a task inside a hazardous envelope, without a written safety procedure.

An energy control policy should be the most critical element driving any safety program. It is like a business strategy plan; deserving much greater attention from both employers and workers.

How to develop an energy control program
You first need to ask yourself one question: Do we need an energy control program? If you operate equipment/machinery that needs to be cleaned, oiled, adjusted, repaired or have maintenance work performed on it, the answer is a resounding yes. According to section 75 of the Occupational Health & Safety Act, this type of work can only be performed when: motion that may endanger a worker has stopped; and any part that has been stopped and that may subsequently move and endanger a worker has been blocked to prevent its movement.

Employers are responsible for developing safe operating procedures that comply with all applicable federal and provincial laws and regulations, and workers must be trained on safety procedures to ensure these are followed at all times. So how do you go about doing this? You select all of the in-house expertise that you have, as well as outside professionals who are practitioners in this field, and develop a set of policies and procedures that address the needs. This comprehensive set of policies and procedures can be called an energy control program/policy, or whatever you like, as long as it establishes the rules of how workers must perform their duties in a safe manner and in compliance with all regulations.

Starting with a visual that is easy to understand, the energy control program becomes the “visual” blueprint that includes all of the elements required to satisfy your specific application; a blueprint that is used as a guide throughout the entire development process. Do not make the mistake of generating material that is dry and requires much reading to arrive at the intended result. Use as many visuals as possible. Visuals are very effective in conveying your message and always increase retention. Although not all blueprints will be the same, similarities do exist from one application to another. Let’s take a closer look at this energy control program blueprint.

Begin by developing or updating your current inventory of equipment/machinery, and then examining all issues of compliance for each piece of equipment or machine type. Keep in mind that the new energy control program needs to satisfy all applicable government health and safety regulations, as well as corporate regulations and standards if these exist. Section 75/76 of the Occupational Health & Safety Act and CSA – Canadian Standards Association Section 7, which relates to Pre-Start Health & Safety Reviews (PSR), is a good place to start before developing any procedure.

Procedures
Written procedures are required, starting with the most commonly practised lockout. Depending on the complexities of your specific equipment/machinery or process, the number of safety procedures will vary. In this particular example, four types of safety procedures are used: Lockout to isolate all energy sources; CAP (control access procedure) to guide the worker through the steps on how to bring a complex machine into a safe state; ASA (approved safety access) to guide the worker on how to gain safe access to a specific area of the machine; and finally the JES (job element sheet) to guide the worker on how to perform a specific task. No procedure can be written until a risk assessment is completed.

Energy maps
Energy maps are visuals that clearly identify all sources of energy for a particular piece of equipment/machine. Typically, the footprint of the equipment/machine is drawn in full colour, clearly highlighting all machine sections, material flow, safety devices (including guards), energy sources and isolation devices. Where multiple sources of energy are used, the sequence of energy source isolation is shown.

Training
Training is a very critical element to the successful implementation of any safety program, and embarking on a new energy control program is no exception. When all the work is completed, training helps to take the message to the workers and, in return, workers must demonstrate that they have the skills required to work with each safety procedure. Training should also provide a system for workers to be re-trained each year, and every company should maintain training records to ensure workers are competent in carrying out tasks safely.

Records
All safety procedures must be reviewed and updated periodically, or when equipment/machinery is relocated or modified. A central location must be identified and a record maintenance system be put in place that can be audited at any time. Document creation date, revision history, reviewer’s name, and the name or names of the approver are shown in records. In the case of PSRs, the name of the engineer who approved the PSR is shown. Records show when safety documents were issued, reviewed and revised, and they make your life easier during regulatory agency audits.

Review
Periodic reviews are a great way to share safety information with workers. They provide a great opportunity to discuss updates, procedure changes, results of risk assessment, PSR approvals and general safety information with workers, keeping them informed.

In summary, any energy control program implementation must address the issues of compliance, types of safety procedures, energy maps, periodic reviews, worker training and records maintenance. Although the detail and complexity of each topic and your energy control program will vary in each situation, the thought process and mechanics of getting there remain the same.

Bill Valedis is the president of Imperial Automation Technologies Inc. You can reach him at bvaledis@precisionservices.ca.