USDOL/OSHA’s standard for lockout/tagout entitled, “The Control of Hazardous Energy,” is found 29 CFR 1910.147.
[Please take note that not all states strictly adhere to OSHA standards. States are free to form their own standards as long as they exceed the standards provided by federal authorities. Some states have their own enforcement for these rules. In order to keep this article brief, it will only refer to USDOL/OSHA standards found in 1910.147.]
While 1910.147 does cover the requirements of any lockout tagout program, the standard does not specifically cover electrical hazards like those found in OSHA’s electrical safety-related work practices standards (1910.333). Those electrical standards provide more guidance for LOTO needs around electrical equipment.
As a general practice, LOTO is a tool used to keep employees performing service or maintenance from coming in contact with unexpected hazards like the release of stored energy or the unexpected startup of equipment.
As far as OSHA inspectors are concerned, performing a task on parts of a machine that could move without first following LOTO procedures isn’t automatic grounds for a citation. The important things to keep in mind is where those parts are versus where the work is being done, and keeping in mind what would happen if the machine were to suddenly move or turn on. If there is no risk for injury if something activates unexpectedly, then LOTO may not be strictly necessary.
One example of this is the service and maintenance of machinery that is connected by a plug and cord. As long as the cord is unplugged and the employee doing the work is the only one with control of the plug, then LOTO rules need not be followed.
However, plug lockout devices are available if there is a need for another layer of protection. Using plugs to avoid LOTO isn’t a way to circumvent the law, but in some instances, it can make sense to ensure the safety of all employees.
Hot tap operations may also fall in the same category if there is no possibility of harm. Hot taps generally deal with transmission and distribution lines for different media like gas, water, steam, and petroleum products. If there is work being done on pressurized pipelines, then there are specially designed gate valve lockout devices as well. Any time that there is energy that could be unexpectedly released, caution is the suggested course of action.
While many normal production procedures will not need to follow LOTO, it’s important to consult 1910.147 to be sure. This article doesn’t have the time to cover the intricate minutia of every single minor task and whether it requires LOTO. When in doubt consult the 1910.147 standards.
When performing operations that require the lock-out of electrical circuits, de-energizing is not enough to be totally safe. There are still hazards that could exist in the form of stored energy, either electrical or mechanical.
Instead, aim for the zero energy state (ZES) or zero mechanical state (ZMS). ZES means that all the energy in the system is in a neutral state. This state can only be reached when all possible problems are addressed. There could be concerns about heat, pneumatics or hydraulics could have residual pressures that could release suddenly, there could be parts that can move with gravity’s influence, springs could be tensioned, or pipes could be pressured.
It is in these situations that LOTO becomes imperative. Using LOTO to eliminate the hazards is the best way to be certain that nothing can go wrong. Following LOTO to reach either a ZES or ZMS may require purging systems, sealing pipes, locking valves, installing blocks, and other measures.
Because employees are more apt to use equipment when they know where to find it, companies often designate a lockout/tagout center. The most common location is the maintenance department or close to machinery that requires LOTO. Those repositories are the home for the company’s collection of padlocks, tags, blocking devices, and other safety hardware.
Once employees have access to the equipment they need, the next step is teaching them how to use it. A full safety lockout program will include documented energy control procedures. This list of tasks spells out the proper steps to lockout the machinery.
A general policy isn’t enough, there needs to be a specific plan for every piece of equipment that needs to be shut down. The few times where safety protocols don’t need to be specific to the machinery are covered in the OSHA standards. Employees need to be trained in how to use these procedures in an emergency situation as well as basic maintenance.
The relevant safety equipment, procedures, and employee knowledge must be inspected regularly. LOTO is meant to serve as a guarantee that a workplace is safe. That guarantee equipment is isolated and inoperable is only meaningful if there all the parts of the program come together.
Training is mandatory for all employees, but not everyone needs the same level of knowledge. There are three different levels of training to give everyone the information they need without wasting time.
Authorized employees receive the most comprehensive training. They are the ones who are able to perform the actual LOTO for that Machine. Who is authorized can change from machine to machine, as each piece of equipment will require additional training.
Affected and other employees are grouped together. They only need to recognize when procedures are in place and being deployed. They need to know why the procedure is important and how to stay away from the equipment while it is being worked on.
Every employee needs to be trained whether they claim to know the procedures or not. The belief that they know what to do does not necessarily correspond with the knowledge of what to do. Even if they have worked on similar machines in a different facility, they need to be trained in your policies. Even machinery that is the same make and model in your facility could have different needs, there could be different addons or alterations that add steps to the LOTO process. The machines could have different energy sources or hookups.
Whenever someone has reassigned roles, a machine is altered, someone notices that proper procedures aren’t being followed, or after an accident, supplemental training will be necessary. All the procedures need to be inspected for continued accuracy at least once a year. The inspection needs to be carried out by an authorized employee, but it can’t be the one who is using the energy control procedures.
All training needs to be recorded with the names of employees and the dates of training. Everything needs to be documented. Whenever training expires it needs to be redone.
The strict, rigid rules of a well-developed safety plan become even more important whenever multiple people get involved. Passing responsibility from one employee to another needs another level of care. Shift changes, for instance, can be hazardous times if not handled properly. If the work goes beyond a single shift, but employees are not immediately handing the keys off to another person, special provisions may be necessary.
For large jobs, there will not only be multiple shifts, but multiple departments involved. When that is the case, each person will have their own LOTO lock, which they all attach to a hasp that has the proper number of holes. As long as work is being done there must remain at least one lock on the hasp. There is no excuse for gaps in coverage.
Safety isn’t a place where you can make assumptions. The employee in charge of a lock needs to know where every member of their team is at all times, and can’t remove their lock until they are sure that all their people are out of harm’s way. If a subcontractor is involved, they will fall under that person’s responsibility as well.
To be absolutely sure that LOTO locks aren’t tampered with, it is common to limit the number of keys that open each lock. Having master keys demeans the entire process. At most, there should be two keys to a lock. One key goes to the employee responsible for the lock and one can go to a supervisor or manager. Those keys are often kept in a dedicated lockbox.
However, the best method is to have locks that only have one key. That negates the possibility of a misunderstanding, or management getting restless. If someone calls in sick and can’t come into work the next day to release their lock, at least the machine is still isolated. In that case, the supervisor needs to talk with that employee to ascertain exactly why the lock is there, what work still needs to be done. Then, if work needs to continue the supervisor can cut off that lock and replace it with a lock of a different maintenance person. They can apply their personal lock, with their personal key, with their personal tag. From there that authorized person is now in charge of the LOTO. Locks can easily be replaced, lives can’t.
The fear of steep OSHA penalties is usually enough to keep companies in line with safety procedures, but the risks to employees are what needs to be thought of most.
When it comes to fines, the maximum amount can shift from year to year. Not only is the maximum number rising, but the actual totals of penalties continue to rise year after year. OSHA has no sympathy, and a single violation will not cause them to stop looking for others. Fines and penalties can stack for violations of several distinct sections of 1910.147. If the offender is lucky, OSHA will group different parts or paragraphs together into one fine. But more often than not, each separate item will carry its own fine. If a citation alleges multiple violations of LOTO standards, it can address non-compliance with the written program, training, equipment, specific procedures, and anything else the inspector sees.
Using the LOTO standards, it’s possible to determine all of the proper lockout tagout kits, locks, and devices and how they need to be applied. These standards specify what these devices should look like and how they should perform. Things covered include how durable the devices must be, the standard colors that are acceptable, the shape, the size, the print, and the format. Both the locks and the tags cannot be made so that they are easily tampered with, removed, or destroyed.
The tag needs to be able to clearly identify who applied it. The LOTO tags need to be simple, and straight forward. They need to convey caution and warning while displaying clear information.
If you want to know where to access the 1910.147 standards, the OSHA web site is a helpful resource. In addition to safety regulations, the association posts interpretations of their rules to aid companies in staying safe and directives by the agency to keep industries up to date.
The government also provides a free template for a new LOTO program. While general, it has all the basic information and all that is required is to customize it to fit your exact machinery. You can also find a sample program in Appendix A of 1910.147 entitled, “Typical minimal lockout procedures.” OSHA.gov provides more specific information about the world of lockout tagout and does deep dives into the subject to help keep everyone safe. Content like training and examples of situations in the field are there as well as downloadable literature. OSHA’s website is great resource for any LOTO program. Your state likely also has free resources and templates of model LOTO programs through consultation programs.