Valid Control Method - Machine specific LOTO (LockOut TagOut) procedures

S

Shannon - 2007

#1
Valid Control Method

Hi all,
:bigwave:
This question is in regards to machine specific LOTO procedures that are posted on the equipment.
Our maintenence dept has completed creating these procedures for over 100 pieces of equipment in the plant. They are printed on orange paper and are glued between two pieces of plexiglas to prevent from getting ruined by water during the many washdowns that we perform.
It was recognized, late in the game, that these instructions did not carry a revision date on them. They are identified with a unique document number and are listed on the Maintenence MCD, which provides the revision history information.

The obvious answer is to start all over again and reprint the docs with the revision date. Because of the additional costs and time to do this, we wantto explore other potential options to bring us into compliance.

Here is one suggestion:
Rewrite our Maintenence Program document that describes the control methods for the Maintenence documents to read. . .
"All LOTO instructions are identified with a unique number, and are printed on colored paper that reflects the revision number."
Revision Code
Revision 1 = Orange paper
Revision 2 = Yellow paper
Revision 3 = Goldenrod paper
Revision 4 = Pink paper

This would enable people to determine if the LOTO instruction was current or not. They could reference the MCD using the color versus the Rev date.
In addition, we expect very minimal changes to these documents, if any. The method for LOTO doesn't change often.

What do you all think?
Is this a valid method for the control of our LOTO instructions?

Shannon
 
Elsmar Forum Sponsor

Cari Spears

Super Moderator
Staff member
Super Moderator
#2
I can't think of any scenario where that would cause a problem. I like the creative thinking!

I would only worry about similar colors like yellow and goldenrod being mistaken for each other if you are using the words and not a little square of the paper color. But, if you know from experience that these documents are unlikely to be revised frequently that should be easy to avoid.
 

CarolX

Super Moderator
Super Moderator
#3
Shannon said:
It was recognized, late in the game, that these instructions did not carry a revision date on them. They are identified with a unique document number and are listed on the Maintenence MCD, which provides the revision history information.
Ok Shannon, here is my take.....Why do you need the rev date on them? They are identified and current rev info can be found in the Maintenence MCD. This may not be the most efficient method for identification of current rev levels.....but......as you said....you realized late in the game this was missing. How about this....toss it into your CA program....with the action to correct the problem will be to add rev info next time the LOTO is revised.

BTW....what does LOTO stand for?

CarolX
 
C

Craig H.

#4
Shannon:

Another way that might work is to say that the first revision is "0", and the Rev number does not appear. Then, when you do have a revision, the doc would become something like "document number 123XYZ082003", the last 6 numbers being MMDDYY.

Either way should work. Whatever is easiest and makes sense to you.
 
R

Randy Stewart

#5
You could put the rev date on a label and stick it on the plexiglas until the doc has to be replaced, then put it on the doc itself. Just a thought. I don't see a problem with the system you define, I would watch out for the color fading over the long term.
One thing I question, if the procedure has to be replaced by a different color, why not print the rev date on the new procedure and forget about the color code? Leave the statement that the original is orange or whatever color and that Rev 1, 2 etc. will be on the document. You'll then get away from the expense of color paper.
 
C

Craig H.

#6
Carol

Yes, putting it in the C/A system is a trick that I... uh, it is a way to say that we know about a problem and are working on fixing it, so we keep certain auditing types from issuing a N/C, and also so we remember that we are supposed to fix it. Ok, mainly so we remember we are supposed to fix it.


;)

Craig
 
#7
LOTO (LockOut TagOut)


Part of the question might be based on what standard you are using. ISO 14001 for example states "Documents shall be legible, dated (with dates of revision)..." 9K2K says "to ensure that changes and the current revision status of documents are identified".

In either case what you have to do is to ensure that the instructions are the relevent ones. In LOTO, this is very critical because body parts are involved.
 

Mike S.

Happy to be Alive
Trusted Information Resource
#8
Randy Stewart said:
You could put the rev date on a label and stick it on the plexiglas until the doc has to be replaced, then put it on the doc itself.
FWIW this is what I'd do as well. You can cover the label with tape so it doesn't get wet. Make sure that whomever might be the person who would open the plexiglass knows what needs to be done as far as the rev. issue so that if an auditor asks everyone is on the same page and so that things get done correctly for safety's sake.
 
D

David Hartman

#9
You could even make the "unique" document number the revision indicator as well (i.e. assign a modified document number to the next revision such as: A301289-1, followed by A301289-2, etc. -or- use an alpha revision indicator if more appropriate). :bigwave:
 
C

CINDY

#10
Shannon,

You could also make a print copy of each LOTO with corrections and place them in a master folder. The master folder could also be the place where you record review dates. You are right in stating that LOTO does not change much.

Cindy
 
Thread starter Similar threads Forum Replies Date
K Document Control - 'Valid Only on Print Date' in Footer (Opinions Requested) Document Control Systems, Procedures, Forms and Templates 2
B IATF 16949 News Six month extension on all valid IATF 16949 certs IATF 16949 - Automotive Quality Systems Standard 10
H PCD remains valid for new product ISO 13485:2016 - Medical Device Quality Management Systems 11
C Neglect or legitimate deferral? Is excessive workload or lack of resources in a department or a team a valid root cause for a non-conformance? Problem Solving, Root Cause Fault and Failure Analysis 12
M Products Manufactured while CE was valid CE Marking (Conformité Européene) / CB Scheme 1
L Valid reasons to omit an "ear-tag" type label on a cable? IEC 60601 - Medical Electrical Equipment Safety Standards Series 1
J Are Capability Requirement(s) Valid for All Characteristics? Capability, Accuracy and Stability - Processes, Machines, etc. 6
M Are ASTM F745 & ASTM F75 still valid? EU Medical Device Regulations 5
Q Is KPI in Process Valid if not supported by Procedures? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 5
K MDD or other EU guidance that describes the need for Valid Production Processes EU Medical Device Regulations 2
T Predicate device recalled - Still a valid predicate device? Other US Medical Device Regulations 7
M Is calibration from long ago still valid on never used pipettes? General Measurement Device and Calibration Topics 8
M FDA 21 CFR 820.250 - Does "valid statistical" always mean math? 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 6
F Sample Size to get Statistically Valid Data Measurement Uncertainty (MU) 6
C Is this GR&R method valid? (Printing Company) Gage R&R (GR&R) and MSA (Measurement Systems Analysis) 4
A CE Certificate is valid until 3.12.2013 - Can I still sell the products in Europe? EU Medical Device Regulations 10
S Statistically valid number of biopsy devices should be tested US Food and Drug Administration (FDA) 4
somashekar Authorization to use shelf life sensitive materials beyond its valid shelf life... Manufacturing and Related Processes 7
V Sample Range for a valid GRR using ANOVA in Minitab Gage R&R (GR&R) and MSA (Measurement Systems Analysis) 2
Q Is it Valid to refer group of documents instead of names? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 9
G Gage R&R Calculation Spreadsheets - Which one here is valid? Quality Tools, Improvement and Analysis 4
P Sterile Packaging Validation - FDA Requirements for Statistically Valid Tests 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 9
K Who issued this certificate and what products it is valid for? ISO 13485:2016 - Medical Device Quality Management Systems 5
K Statistically Valid Audit Sample for Management System Audits? Inspection, Prints (Drawings), Testing, Sampling and Related Topics 4
H ISO 9001:2000 Certificate - Original approval date 18 July 1995 and valid until 2012 ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 27
W How long is a Medical Device product registration in Iran valid for? Other Medical Device Regulations World-Wide 1
R Is Cpk valid for a sample size of "1"? Capability, Accuracy and Stability - Processes, Machines, etc. 5
S ISO/TS 16949 certification no longer valid when automotive part production ends? IATF 16949 - Automotive Quality Systems Standard 7
P Valid NB Technical Review Nonconformance? New Class IIb Product EU Medical Device Regulations 4
B Is ISO 14971:2007 still a valid standard? ISO 14971 - Medical Device Risk Management 9
S Without Surveillance Audit, Is ISO certification still valid? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 8
R Is Cpk calculation of dBA (noise level) valid? Capability, Accuracy and Stability - Processes, Machines, etc. 9
Q How long is ISO 9001:2000 good for (valid) ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 2
Q Is my Cpk calculator answer valid? Capability, Accuracy and Stability - Processes, Machines, etc. 4
6 Why the general Valid period of QMS certificate is 3 years? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 8
M Do we need to cite applicable clause of ISO9001 std for a valid customer complaint Customer Complaints 8
S Statistically valid method for multiple raw material sampling Inspection, Prints (Drawings), Testing, Sampling and Related Topics 4
H How to Select a Statistically Valid Sampling Plan Inspection, Prints (Drawings), Testing, Sampling and Related Topics 10
R Valid Date to Close Internal Audit Non-conformance Internal Auditing 1
P MIL-STD 1235C - Is it still Valid or has it been Superseded by another Standard? Inspection, Prints (Drawings), Testing, Sampling and Related Topics 2
D SICMMSE - Is This Accreditation for ISO 17025 Valid? ISO 17025 related Discussions 5
K Valid Food Safety Objectives Food Safety - ISO 22000, HACCP (21 CFR 120) 11
R Rubber Initial & Inspection Stamps - Valid or a violation of FDA quality guidelines? Inspection, Prints (Drawings), Testing, Sampling and Related Topics 2
B OEM Signed PSW - How long is it valid? What are Ford requirements? APQP and PPAP 7
S Medical Device Industry Corrective Action Techniques - Is 8D valid method? Nonconformance and Corrective Action 4
Sean Kelley Is ppm calculation valid or invalid for bulk materials? IATF 16949 - Automotive Quality Systems Standard 4
T Is Poka-Yoke Old Hat? Is Poka-Yoke still a valid concept? Nonconformance and Corrective Action 28
A Is reduction of scrap a valid Continual Improvement Project? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 7
A How Long Will QS-9000 be 'Valid'? QS-9000 - American Automotive Manufacturers Standard 11
D Valid study for CO samples both Analyzer and Drager Tube results? Statistical Analysis Tools, Techniques and SPC 1

Similar threads

Top Bottom