Summary

In Quebec, under section 188.2 of the Regulation respecting occupational health and safety (ROHS), a lockout procedure or, failing that, “any other method that ensures equivalent safety” must be applied when undertaking any non-production work in the danger zone of a machine. “Non-production work” refers to any operations related to those mentioned in section 188.2 of the ROHS. The purpose of such work methods is to control hazardous energy associated with the equipment in order to prevent any accidental release of energy and therefore any possible injuries. The obligations of Quebec establishments with respect to controlling hazardous energy during non-production work were laid out in early 2016, when sections 188.1 to 188.13 were added to the ROHS.

The Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST) has revealed that between 2010 and 2014, an average of around 4 deaths and 1,000 accidents occurred annually in Quebec in the course of work on equipment where the energy was poorly or not at all controlled. Most of these accidents could have been avoided if appropriate preventive measures such as lockout or an equivalent step had been taken. Earlier studies on this topic by the Institut de recherche Robert-Sauvé en santé et en sécurité du travail (IRSST) found that organizations had trouble implementing lockout (e.g., drafting and applying procedures, auditing).

In a previous study, it was noted that mobile equipment (i.e., self-propelled, towed or transported machinery or equipment) is rarely covered by lockout programs, even though it is a potential source of serious accidents during non-production work. Regulatory requirements governing the control of hazardous energy concern mobile equipment in the same way as stationary equipment. The study’s main objective was therefore to monitor, assess and review an approach to implementing lockout for mobile equipment in the non-production stage in the municipal sector. This applied study included a practical implementation stage.

The results of the study are based on (1) an analysis of serious and fatal accidents, (2) a review of the literature, (3) an analysis of current practices in the municipal sector and those of a supplier and (4) 18 months of monitoring a municipality’s mechanical shop during its implementation of the lockout procedure for mobile equipment. The issues identified are grouped together and discussed under four headings: (1) raising stakeholders’ awareness, (2) managing lockout implementation projects, (3) developing lockout procedures and (4) managing work using a method other than lockout.

An analysis of serious and fatal accidents in all industries in Quebec between 2000 and 2013 identified 56 deaths on mobile equipment in the course of non-production work. This number accounted for 7.6% of the serious and fatal accident investigation reports for the study period. In most cases, the accident involved unplanned work by the vehicle operator (e.g., work while the motor was running) or mechanic (e.g., stalling problem). The three main types of accidents (that is, falling from elevated equipment, moving part and moving mobile equipment) were directly related to a problem applying the lockout procedure. Raising the awareness of mobile equipment managers, foremen, mechanics and operators of the hazards associated with non-production work on mobile equipment is therefore crucial.

The participating municipality’s implementation process was analysed with reference to the 11-step implementation plan proposed by the Association paritaire pour la santé et la sécurité du travail, secteur “affaires municipales” (APSAM) [joint occupational health and safety association for the municipal affairs sector]. The issues involved in the management of the lockout implementation project were the availability of resources, the scope of the project, resistance to change and support for the project.

When following a lockout procedure, simply using the mobile equipment’s ignition key is not sufficient to ensure the steps of isolating and locking out. Using the ignition key is not a substitute for applying a personal padlock, for two reasons: ignition keys do not act on energy cutoff devices and they are not unique. They are more of an alternative method. Going down a generic checklist prior to starting work instead of following a proper lockout procedure does not meet regulatory requirements, either. Thus, the main factors likely to change mechanics’ current work methods are following a specific lockout procedure, using a personal padlock and affixing information tags.

With regard to energy control procedures, the report proposes an equipment-based approach. Following an inventory of hazardous energy sources, cutoff points and non-production work associated with the equipment, a standard lockout procedure can be drafted. Targeting work on equipment where standard lockout is not a suitable solution is then recommended. Among special situations, the following types of work can be specified: work in which energy is required (e.g., diagnosis), short, minor work in a repair shop (e.g., replacing window wipers) and jobs required on site to allow production work to continue (e.g., unjamming the chute of a snow blower). For these kinds of jobs, energy control methods other than lockout (e.g., safe shutdown) could be used, based on the manufacturer’s instructions, the mechanics’ experience and risk analysis.

The report proposes incorporating the results and discussions into the APSAM’s lockout implementation plan and makes recommendations regarding the vocational training of mobile equipment operators, mechanics and designers. Last, it suggests that Quebec mobile equipment manufacturers and suppliers should adhere to the principles of the ROHS and standard CSA Z460-13, especially regarding the content of user manuals and the incorporation of energy cutoff devices that can be locked out, in accordance with standard IEC 60204-1.

Disseminating the results of this study will help (1) prepare organizations and sectors that want to implement lockout on their mobile equipment fleets, (2) provide organizations with the hazardous energy control knowledge they need to buy mobile equipment and (3) raise mobile equipment suppliers’ awareness about lockout.