Archive for the ‘Blogroll’ Category

What is a Program?

Wednesday, May 21st, 2014

I recently spoke at the AFPM Occupational & Process Safety Conference. It was a great event, with lots of real-world knowledge getting shared, good products being presented, and all in all, just a fun bunch of professionals getting their safety on.   Besides evangelizing on my company’s products, I always also learn about market trends, forces, and most importantly, mindsets. As a consultant and entrepreneur, it is critical that I be aware of, and I react to, people’s preconceived notions. If their notions are valid, I am a fool if I do not pay attention and re-align my company’s products to encompass this new knowledge. If their notions are invalid, or founded upon misinformation, it is just as critical that I re-educate them, as gently as possible.

Through the years, as I have worked to spread the word about DangerTags, I have frequently run into situations where prospects (typically management) told me “we have that already”, or more commonly, “we already have a LOTO program”. I found this discouraging, because I really thought we had innovated and were delivering something to the market that was new and a valuable tool to provide a solution to a very real problem. Oddly, I would then speak to someone else in the same facility only to discover that they had nothing like DangerTags in place. I found this disconnect between managers and operators frustrating and almost inexplicable. There is no way one person could be under the impression that they had LOTO automation in place, with their direct report just as confidently saying that they did not. As time has passed, I have found that there was a communication breakdown between myself and prospects, surrounding the definition of the word “program”. As usual, I was most of the problem.

My name is Keith and I am a recovering programmer. As we all know, programmers program programs. No ambiguity there, right? That is, until I go to my kid’s elementary school musical and somebody hands me a program. Disturbingly, this is a program that doesn’t run on a computer. This strange object frightens and bewilders me. Where is the code for this program? My reality collapses as people repeatedly refer to the pamphlet as a program. Well, guess who is the moron here? Here’s a hint: it’s me.

My new expanded reality makes it clear that a program can describe a process and documentation standard. This, of course, almost every plant in the world has in place. Well thought-out and very detailed programs in which someone has a great deal of time invested. These are vital documents that represent corporate standards that are not to be ignored and certainly not discarded. So when I come in and start talking about our LOTO automation program, if I don’t make myself clear, I can rightfully expect resistance from the owners of these processes. They do have a program in place, and it works, and therefore is not lightly replaced. Which leads us to my next communication failure: DangerTags does not replace the existing program.

Every time we go into a new facility, we customize DangerTags to produce lists and tags in the format that facility has always used. We find that when the staff in the field sees a document that looks familiar with the only difference that it is more legible, it increases comfort and therefore buy-in from the people on the ground that have to use the system every day. So, DangerTags simply takes the laborious handwritten processes of the existing program and automates their production. In a facility where not only tags are handwritten, but lists are as well, the labor savings is huge but the increase in efficiency and safety is the big deal. Being able to easily reproduce a list that exactly matches the set of printed tags is a massive improvement in the program. Our program becomes a part of their program. And my grasp of the English language becomes a little better.

The Most Stupid and Dangerous Thing Our Goverment Has Ever Done

Wednesday, April 30th, 2014

I know my blog is typically focused on LOTO excellence, but I have to briefly use my platform to make an attempt to protect our nation from harm.  From time to time, our government does stupid things.  Democrats and Republicans can all agree on this point, even though the “stupid thing” may differ.  A few weeks ago, our government did something that is so stupid, so incredibly short sighted, that Democrats, Republicans, Libertarians, and Independents should all be outraged.  This ridiculous act will not only further diminish the US as a world power, but stands to destroy freedom of speech as well as our economy.  Our government decided to relinquish control of the Internet.   Yes, you heard right.  The communications network that ties the whole world together, enables our businesses, houses our healthcare data, connects the smart power grid, and stands as the largest source of free speech in the world and the history of mankind.  Our government felt like it was a good idea if we allowed an as yet unnamed multinational group to take control. 

 Some things can’t be argued. For instance, the US invented and built the Internet.  Going back to the ARPANET days, we engineered and built the lowest foundation of it all.  The physical infrastructure, the naming systems, the security systems, the transmission protocols – are all American made.  Not just engineered by American minds; funded by American taxpayer dollars.  Al Gore didn’t invent the Internet, but he did play a significant role, notably his sponsorship of the legislation called the High-Performance Computing Act of 1991.  That one piece of legislation alone, signed into law by George H. W. Bush on December 9th, 1991, appropriated billions of US taxpayer dollars to the development and construction of the “Information Superhighway” which eventually became the Internet that we all know and love today.  That’s right; it was authored by a Democrat and signed into law by a Republican.  Remember when our government used to get things done that way?

 Since then, the Internet has been controlled by a non-profit group of incredibly intelligent individuals called ICANN, the Internet Corporation for Assigned Names and Numbers.  Your IP address, your website address, your email address, and every other one are managed by them.  The security systems that protect you and your data are managed by them.  The plumbing that lets you browse the web, send emails, pay your bills, your Facebook, your LinkedIn, your Instagram, your Twitter, your Reddit, are all capably managed by this group of the best and brightest.  It is not just Americans any more.  There are people of many nationalities, so the world is represented.  But, what is of paramount importance is that this group has been contracted by the US government.  Most importantly, funded by a country that has a First Amendment.  Does our government think that giving up control to someone who doesn’t have a First Amendment is going to increase openness and freedom on the Internet?  If they do, we are back to stupid again.  As I mentioned earlier, ICANN is a non-profit organization.  How would you like to start paying more fees for your Internet service?  Would you like to pay those fees to China?  Maybe Russia?

 As an American and a fan of freedom, I must request that every one of you write or email your Senator, your Representative, and any other government employee you so desire and protest this decision.  For a moment, please forget Bengazi, Obamacare, the Tea Party, the IRS Scandal, Flight MH370, and the Ukraine.  Our country is placed in far greater jeopardy by this decision.  It is time for us to all be Americans and demand what is best for America.

Safety Facility Management Stats – October 2009, page 18 -21

Wednesday, October 28th, 2009

Lockout/Tagout is a major OSHA-inspection focus. In fact, it’s the #1 most cited violation for general industry. But, rather than focus on the negative aspect of noncompliance and citations, focus instead on this; comprehensive and thoroughly-followed LOTO programs:

• SAVE LIVES – preventing an estimated 250,000 incidents, 50,000 injuries and 120 fatalities annually;

• CUT COSTS – significantly; both lost employee time and insurance costs;

• IMPROVE PRODUCTIVITY – minimizing equipment downtime;

• BEST PRACTICE – being widely adopted across industries and industrialized countries

 

The following are actually specific incidents that happened involving a faulty LOTO system:

Program Development and Procedures

Synopsis of Regulatory Standard: According to 29 CFR 1910.147 (c)(1), the employer is to establish an energy control policy/program consisting of energy-control procedures, employee training and periodic inspections to ensure that the machines or equipment are properly isolated from their energy sources, and rendered inoperative prior to any servicing or maintenance.

29 CFR 1910.147 (c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in locking out equipment. A separate procedure must be created for each piece of equipment, or each group of similar equipment as defined, except for equipment that meets a rigid set of exceptions.

Related Incident & OSHA Citation: October, 2007; OSHA proposed $112,500 in penalties to a large employer for repeat violations, including failure to develop proper energy control procedures.

Less than three months earlier, the same organization was cited for $2.78 million in proposed fines for 42 willful violations of the lockout/tagout standard, including failure to utilize lockout procedures before attempting to clear equipment jams, and failure to provide training to four employees responsible for clearing jams. Tragically, an employee had been killed in a related accident.

Successful Program & Procedure Development: The written lockout policy is your starting point; it establishes the ‘nuts and bolts’ of your overall lockout program. Begin this by over viewing and then documenting your program; continue with machine-specific procedure development, training and periodic inspections. OSHA has a Lockout/Tagout Tutorial on its www.osha.gov website that provides additional advice.

Also see Brady’s Lockout Pro Graphical Lockout Procedure Software for a thorough sample energy control policy that can serve as a guide as you develop your own comprehensive energy control program. However, the overriding benefit of Lockout Pro is that it allows you to create and manage clear & easy-to-follow visual machine-specific procedures for all your equipment.

Energy Control Points

Synopsis of Standards: According to 29 CFR 1910.303 (e) and (f) Subpart: Electrical, all disconnecting means must show the magnitude and shall be legibly marked to indicate the purpose.

ANSI Z244.1-2003, Control of Hazardous Energy, states that all energy isolating devices should be adequately labeled or marked unless they are located so that their purpose is clearly evident. Identification shall include the machine supplied and the energy type and magnitude.

Related Incident & OSHA Citation: November, 2002, OSHA cited a manufacturer for failing to protect workers from electrical hazards that contributed to the death of a worker. The employee was working on electrical equipment that had not been properly labeled and disconnected. OSHA issued a willful citation for failing to properly label electrical equipment, and a serious citation for failing to have adequate procedures in place to render machinery inoperable while maintenance and repair work were performed.

Successful Energy Control Point Identification: Locate and mark all energy control points, including valves, switches, breakers and plugs, with permanently placed labels or tags. Cross reference each label and tag with the corresponding step number in the posted energy control procedure for that equipment. Include information about the magnitude and purpose of the control point as stipulated by OSHA for electrical disconnects and recommended by ANSI for all isolating devices.

Training, Communication & Inspections

Synopsis of Standard: 29 CFR 1910.147 (c)(7) requires an employer to provide training to ensure that the purpose and function of the energy control program are understood by employees … (iv). The employer shall certify that the employee training has been accomplished and is being kept up to date …

Standard: 29 CFR 1910.147 (c)(6) The employer shall conduct a periodic inspection of the energy control procedure at least annually.

Related Incident & OSHA Citation: August, 2007, OSHA conducted an investigation following the death of a fleet mechanic who was pinned between two trucks while performing maintenance on one of the vehicles at the company’s worksite.

“This was a preventable tragedy” stated the director of OSHA’s area office. OSHA issued one willful violation for alleged failure to implement and train employees on a lockout/tagout program to be used when performing vehicle maintenance.

Successful Training, Communication & Inspections: First, establish formal training programs for each of the three categories of employees for lockout: ‘Authorized’, ‘Affected’ and ‘Other’ employees. OSHA provides advice on how to train, and verify that the training is up-to-date.

Programs like Brady’s Lockout Pro includes a training module and employee quiz that can be administered upon completion of your employee training. It also provides a straightforward explanation of the periodic inspection requirements.

Proper Protective Products

Synopsis of Standard: 29 CFR 1910.147 (c)(5) says lockout devices must be provided by the employer, be standardized by size, shape or color, be distinguishable from locks used for other purposes, identify the individual who applied the lock, be durable, be strong enough to prevent removal except by using excessive force, and remain under the exclusive control of the individual who attached them.

29 CFR 1910.147 (c)(5)(iii) says that tagout devices shall warn against hazardous conditions if the machine or equipment is energized and shall include a legend such as the following: Do Not Start … Do Not Operate.

Related OSHA Citation: March, 2007, OSHA opened an investigation after receiving notification that an employee was crushed while servicing a hydraulic press that had been disabled but not protected against accidental energizing by locking out potentially hazardous energy sources.

OSHA issued four willful and 15 serious citations, alleging, in part, that the company failed to control potentially hazardous energy during machine repair or maintenance, and was deficient in having personal identification of lockout devices.