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1️⃣ Bad or outdated templates.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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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.

A good part of our career has been spent in ag-business/agribusiness operations, with a huge part of them being at feed mills- for both day and night shifts. This episode covers a few big ticket items that we routinely see. This list can help raise a red flag that there may be some significant risk that can lead to an injury on the horizon. We hope this helps!

Summary
In this episode of Safe, Efficient, Profitable, Joe and Jen break down mill safety risks. Core themes and topics discussed: housekeeping & dust control, bin cleanouts and confined space, alone-worker protocols & site security, auger/elevator hazards, and lockout/tagout realities. They emphasize seasonality (winter/ice, summer humidity, harvest chaos), contractor scheduling, and how documentation (permits) exposes program gaps.

Action Checklist (use on your next mill walkthrough)

Verify dust/housekeeping program- anything requiring contractors, coordinate to manage seasons & contractor/part lead times.

Spot-check bearings/heat and guard integrity at augers, hammer mills, headhouses etc

Review the last 5 confined space permits —do training, equipment, and rescue plans line up? If not, give us a call! www.allen-safety.com

Evaluate alone worker processes, check site security (fences, locks, access points near rail lines) and work in a plan to tighten things down where you're able.

Walk equipment that routinely must be cleaned out, troubleshooting is required, jams, etc and validate LOTO is correct- where to apply the lock, how and who is checking for power.

Safety Training and Training-Style Floor-Based Safety Audits/Evals: Allen-Safety.com
Online safety training: AllenSafetyCoaching.com

Please Like & Share to support us putting out this free worker-safety content.

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Secondary (long-tail / intent-rich):

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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.

Chemical safety: sounds straightforward, right? You’ve got your SDS, PPE, and eyewash stations. But what happens when your team mixes, sprays, or supercharges those chemicals in ways the manufacturer never imagined? With a CHMM on the mic, this is part coaching, part humor, and 100% actionable.

Key Takeaways –

1. The SDS might not be helpful based on how youre using the chemical.

• Reality check: Most Safety Data Sheets are written based on lab conditions and "intended use"—not how your sanitation team might be using them.
• Pro Tip: Ask yourself, “Was this SDS written by someone who’s ever worn PPE, on a harvest room floor, at 2 AM?” Maybe not.

2. Exposure Limits Are Great—If You Can Measure Them

• Common failure: SDS says “use respirator if above X ppm.” Great. Now… how are you measuring ppm in your facility?
• Real examples:
  • No meter for that specific chemical
  • Using outdated Dräger tubes that are non-specific

3. “More Isn’t Better”

• Scenario: You double the chemical strength during deep cleaning due to finding some "buggies." Now your PPE, risk profile, engineering controls—all need to change. Did they?
• Surprise consequences:
• Equipment degradation because the stronger solution wasn’t considered $$$
• PPE may not be adequate for the levels used

4. Training Misses the Human Factor

• You’ve trained on:
  • Where the SDS is
  • How to handle and/or mix
  • Which PPE to wear
• But you forgot to train on:
  • What happens when the goggles fog up
  • That instinctive move to scratch your eye with a gloved hand
  • Spraying above your head and having chemical rain down your back

5. Eyewash Stations: Functional on First Shift, ???? On Off Shifts

• Classic issue: “We check them every Monday at 9 AM.” But chemical use spikes on nights, weekends, and during deep cleans
• Also overlooked:
  • Eyewashes with scalding hot water
  • No eyewash where non-routine chemical usage occurs

Actionable Advice :

• Revisit every chemical on-site: How is it used, applied, stored, and disposed? Does that match the SDS?
• Evaluate your meters: Can you measure the chemical levels you're basing levels of PPE on?
• Update PPE assessments based on how chemicals are used
• Retrain your teams with realistic, scenario-based walk-throughs
• Audit all eyewash stations across all shifts, all departments, and all rarely used rooms

Final Words from Joe & Jen:

• We’re not saying you have these problems. We’re saying we’ve seen them—a lot.
• These gaps sneak in when paperwork replaces field observations.
• If you need help identifying these gaps, we do onsite audits, coaching, and training at AllenSafety.com and AllenSafetyCoaching.com.

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