What Makes A Safety Program OSHA Compliant?

lockout tagout page April 30, 2022 3 min read

Lockout tagout compliance is an extremely important component of any business that has employees exposed to hazardous energy while servicing and maintaining equipment and machinery. Failing to do so can not only expose your organization to fines and other penalties, but it can put your employees at serious risk of physical harm. If you are thinking of purchasing a lockout tagout kit, it is also important to take a broader look at your compliance efforts as a whole.

Ultimately, you must comply with OSHA’s regulatory standard on the control of hazardous energy sources (lockout/tagout). The regulatory standard provides comprehensive guidance on how to create a robust lockout tagout program. That said, even if you have heard of OSHA’s regulatory standard on this issue, you may not be sure whether your lockout tagout locks or safety program is OSHA compliant.

As you likely know, OSHA (which stands for the Occupational Safety and Health Administration) is a U.S. Department of Labor agency that sets and enforces standards to ensure safe and healthy working conditions for all employees. In terms of lockout tagout compliance, OSHA has set forth a specific regulatory standard—called 29 CFR 1910.147—that addresses the necessary procedures to control hazardous energies in your business. 29 CFR 1910.333 is also relevant if you have employees working on electric circuits and equipment. Because it is the employer’s responsibility to protect employees from hazardous energy sources, following the OSHA standard is in your and your employees’ best interest.

Looking at OSHA’s guidance on 29 CFR 1910.147, you can see that there are several minimum performance requirements for the control of hazardous injury. While you will want to look at the entire standard yourself to ensure that your lockout tagout locks and safety program are in full compliance, some of the more significant requirements include:

Ensuring that new or overhauled equipment is capable of being locked out. Using only lockout tagout devices that are authorized for the particular equipment or machinery and ensuring that they are durable, standardized, and substantial. Ensuring that lockout tagout devices identify individual users. Establish a policy that permits only the employee who applied a lockout tagout device to remove it. That said, 29 CFR 1910.147(e)(3) says that if the specific employee is not available to remove the device, it can be removed under the direction of the employer—so long as specific procedures for removal have been developed, documented, and incorporated into the employer’s energy control program. Provide effective training as mandated for all employees covered by 29 CFR 1910.147.

Once again, this is just an excerpt of the required procedures and systems to make your lockout tagout program OSHA compliant. Not only will you want to take a full look at OSHA’s regulatory standard, but you will likely want to speak to your company’s legal counsel to ensure that you comply.

Ultimately, however, much of OSHA’s guidance on lockout tagout assumes that complying businesses have developed thorough compliance procedures. These procedures must be formally documented and cover all affected equipment. If you haven’t done so already, you are at serious risk of being non-compliant with OSHA’s regulatory standard under 29 CFR 1910.147(c)(4). You can look to that section of the standard to see the specific procedures you need to document.

For instance, some of those procedures include specific steps for the placement, removal, and transfer of lockout devices and the responsibility for them (29 CFR 1910.147(c)(4)(ii)(C)) and specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures. (29 CFR 1910.147(c)(4)(ii)(D)).

Along with written procedures, consistent training is expected. You can look to 29 CFR 1910.147(c)(7) for the specific training requirements. When lockout tagout systems are used, certain employees must have a basic understanding of how tags are used and their overall purpose to keep employees safe. Critically, employees must be retrained—per 29 CFR 1910.147(c)(7)(iii)—whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in energy control procedures. Because of this, you must keep a close eye on whether any major changes in your business require retraining. If you have any doubts, it is likely in your best interest to go forth with retraining.

As with any type of compliance program, you will need to complete your due diligence to ensure that your lockout tagout kits and overall safety program are OSHA compliant. By being vigilant, however, you will mitigate your risks of non-compliance and sufficiently protect your colleagues from hazardous energy.

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Rowin Mandia


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