A lockout tagout procedure is a critical occupational safety protocol in preventing unexpected start-ups and the release of stored energy, which can lead to severe injuries or fatalities. Its importance is widely recognized across industries, yet common mistakes in hazardous energy control procedures continue to occur. This article highlights eight frequent lockout tagout (LOTO) errors, offering practical tips for employers and safety officers to avoid these pitfalls and maintain a safer work environment.
Key Takeaways
- Correctly identifying and verifying all energy sources is critical in lockout tagout procedures to prevent serious accidents and ensure occupational safety.
- Regular, comprehensive training for all employees, refreshed periodically, is key to proper adherence to LOTO procedures.
- Strict adherence to LOTO protocols and regular audits are essential to prevent violations and maintain a safe, accountable work environment.
Compliance with OSHA Lockout Tagout Standard Today
OSHA Standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) establishes the requirements for controlling hazardous energy during the servicing and maintenance of machines and equipment. The standard mandates that employers develop, implement, and enforce energy control programs to ensure that machinery cannot be accidentally activated, which could lead to severe injuries or fatalities.
In FY 2022, lockout tagout ranked sixth on OSHA's list of Most Frequently Cited Standards, with a total of 2,554 violations. This indicates that despite its importance in preventing LOTO accidents, many employers still struggle to implement effective lockout programs. Common violations include inadequate training, incomplete procedures, and failure to properly isolate energy sources.
Lockout Tagout Standard Updates
The most recent updates to the LOTO standard have focused on incorporating technological advancements, particularly in the use of computer-based controls for hazardous energy. The current lockout tagout standard was initially designed to address traditional forms of hazardous energy control, but the increasing use of computerized systems has created a need for revisions. This has led OSHA to consider updating the standard to better align with modern practices and international standards that govern these technologies.
In the Spring 2023 regulatory agenda, OSHA moved this potential update to "long-term actions," indicating that while it remains on the agenda, it is not expected to be finalized in the near term. A notice of proposed rulemaking could be released as early as August 2024, but this date is tentative and could be pushed further depending on the regulatory process.
The updates aim to address the growing number of variance requests OSHA has received regarding the use of these advanced control systems, highlighting the need for clear and updated guidelines to maintain worker safety in environments that utilize modern technologies for energy control.
Real-World Cases of LOTO Mistakes
Case Study 1: Sausage Manufacturer
In the case of the sausage manufacturer cited for repeated lockout tagout violations, OSHA's investigation revealed significant lapses in the company’s safety practices. The company was found guilty of multiple repeat violations, including failing to properly de-energize equipment before maintenance, inadequate employee training on LOTO procedures, and neglecting to conduct periodic inspections of energy control protocols.
These oversights put workers at serious risk of injury from unexpected machinery startups, illustrating a systemic failure in the company’s occupational safety management.
Important LOTO Procedures to Implement:
- Thorough De-Energization: It is crucial to ensure that all machinery is fully de-energized before any maintenance work begins. Even a small oversight can lead to severe injuries.
- Comprehensive Training: Workers must be adequately trained on lockout procedures to understand the risks and correctly apply safety measures. Continuous and updated training is essential.
- Regular Inspections: Periodic reviews and audits of your energy control program are necessary to identify and rectify potential weaknesses in the system, helping to uphold compliance and maintain safety standards.
Case Study 2: Chemical Processing Plant
At a chemical plant, a failure to properly isolate energy sources during maintenance led to a hazardous exposure incident. Maintenance workers were replacing orifice plates on lines carrying "sour water," but due to a lack of a written procedure and poor communication, one valve at the tank storage farm was not properly locked out.
As a result, when workers opened the line, they were exposed to a stream of sour water. OSHA's investigation revealed that specific lockout procedures were not followed, and the workers were inadequately trained.
Important LOTO Procedures to Implement:
- Written LOTO Procedures Are Essential: Always have detailed, written procedures for specific maintenance tasks to prevent critical steps from being overlooked.
- Verify Lockout Tagout: Physical verification of lockout/tagout is crucial to ensure all energy sources are fully isolated before work begins.
- Proper Training Is Critical: Employees involved in lockout/tagout must be trained beyond the level of an "affected employee" to handle such operations effectively.
- Documentation Is Key: Retain blanking and tagging lists post-job completion to trace actions and prevent similar incidents in the future.
- Communication Failures Can Be Costly: Clear, verified communication between operators is necessary to prevent misunderstandings that can lead to serious accidents.
8 Most Common Lockout Tagout Procedure Mistakes
1. Failure to Identify All Energy Sources
If you fail to identify all energy sources, then hazardous energy from the equipment won’t be 100% isolated. This mistake often stems from an incomplete understanding of the types of energy present in machinery and equipment. It’s not just electrical energy that needs to be controlled; mechanical, hydraulic, pneumatic, and thermal energy can also pose significant risks.
Examples of energy sources from different categories:
- Mechanical Energy: Rotating parts such as gears, belts, or pulleys that can continue to move after the machine is powered down. Springs under tension or compression that can release energy unexpectedly.
- Hydraulic Energy: Pressurized hydraulic fluid in hoses, cylinders, or accumulators that can cause movement or ejection of parts when released. Hydraulic presses or lifts that can drop suddenly if the hydraulic pressure is not properly controlled.
- Pneumatic Energy: Compressed air in lines, tanks, or cylinders that can cause unexpected movement of pistons or tools when released. Air-powered tools or equipment that can activate if the air pressure is not fully released.
- Thermal Energy: Heated surfaces or fluids, such as those in boilers, heat exchangers, or steam lines, which can cause burns or explosions if not cooled properly. The residual heat in components or materials that can cause burns or fires if not fully dissipated.
A thorough energy assessment is crucial to ensure that all potential sources of hazardous energy are identified and properly isolated. Therefore, implement a comprehensive energy audit for each piece of equipment. Use energy control diagrams and checklists to verify all energy sources are identified. Update these assessments regularly as new machinery or processes are introduced.
2. Failure to Train All Employees
Without comprehensive training, employees may not fully understand the risks associated with hazardous energy or the correct procedures for isolating and securing it. Many companies emphasize training for employees who directly interact with equipment—those who apply locks and tags, known as "authorized employees," and equipment operators, referred to as "affected employees."
However, there’s a third group that also requires training: "all other employees." These individuals, even though they don’t operate or service the equipment, need to be aware of hazardous energy control procedures, especially if they are in the vicinity of potentially hazardous stored energy sources.
The training must cover the purpose of lockout tagout procedures, the risks associated with hazardous energy, and the importance of not tampering with locks and tags. Additionally, training should be conducted initially upon hiring and regularly refreshed—at least annually or whenever there is a change in job assignments, equipment, or procedures.
3. Failure to Develop and Implement Written LOTO Procedures
Every piece of equipment or process should have a specific, written lockout tagout procedure that details the steps necessary to safely control hazardous energy. Generic procedures often fail to account for the unique characteristics of different machines, leading to oversights and errors.
Develop detailed LOTO procedures tailored to each piece of equipment. Include step-by-step instructions, necessary tools, and specific energy control points. Ensure that these written procedures are easily accessible to all employees, whether posted near equipment, available digitally, or provided in multiple languages. This accessibility empowers workers to quickly reference and follow procedures, reducing the risk of LOTO accidents and promoting safety compliance.
4. Incorrect Use of LOTO Locks and Tags
Even when LOTO procedures are in place, the incorrect use of LOTO locks and lockout tagout tags can render them ineffective. This includes selecting the wrong type of lock, improper application, or neglecting to inspect and maintain these energy control devices.
Some locks may not be tamper-resistant enough, or may not be compatible with the machinery being serviced, which could allow unauthorized access and potential re-energization of equipment. Similarly, using the wrong type of tag or placing it in an inconspicuous location can result in critical safety warnings being missed by workers.
There are four general types of safety tags: Danger, Warning, Caution, and Notice, each serving a specific purpose. Issues arise when danger tags or lockout tags are mistakenly used as general information or warning tags, which can lead to confusion and undermine occupational safety protocols. All ‘Danger Do Not Operate’ tags should only be used for the purpose intended.
5. Using Other Worker’s Locks and Tags
Energy isolating devices should be exclusively controlled by the authorized employee doing the energy control procedures. It may seem like a minor infraction, but allowing another worker to use or apply lockout locks and tags introduces the risk of miscommunication and errors.
However, there are limited exceptions, such as when the authorized employee who applied the energy isolating device is unavailable to remove it. In such cases, the lockout device can be removed, but only with employer approval and strict adherence to pre-established procedures. This is provided that particular removal processes and training have been devised, recorded, and included in the employer's energy control program.
6. Ignoring Energy Isolation Verification
One of the most critical steps in the lockout tagout process is verifying that all energy sources have been effectively isolated before beginning any work. Simply locking out a machine is not enough–verification makes sure that the energy control is complete and that no residual energy remains that could cause unexpected equipment activation.
Common techniques for verifying energy isolation include:
- Operating machine controls to confirm that it does not start
- Using multimeters or testers to check for the presence of voltage in electrical systems
- Monitoring pressure gauges in hydraulic or pneumatic systems
- Conducting thorough visual inspections of all lockout points
Implement a standard verification process, such as the Lockout Tagout Tryout (LOTOTO), which includes testing the equipment to ensure it is completely de-energized. Verification should be a mandatory step in all LOTO procedures.
7. Lack of Regular Procedure Review and Audit
OSHA mandates annual audits and reviews of lockout tagout procedures to make sure they are not only effective but also fully understood and correctly followed by employees. These lockout tagout audits are crucial for identifying potential issues or gaps in the energy control procedure, allowing organizations to address them proactively before any accidents occur.
Lockout procedures can become outdated as equipment, processes, and regulations evolve. Without regular reviews and audits, these procedures may fail to address current risks, leading to unsafe conditions. Regular LOTO procedure reviews help reinforce occupational safety practices, maintain compliance, and promote consistency in applying the correct procedures.
8. Complacency During Shift
Complacency often leads to shortcuts, such as skipping critical steps in the LOTO process or neglecting to verify energy isolation, which can increase the risk of LOTO accidents. This behavior can erode the organization's safety culture, as other workers may adopt the same lax practices.
In some cases, complacency may also contribute to a false sense of security, where workers believe that because they have performed a task many times without incident, they no longer need to follow procedures as strictly. This mindset is particularly dangerous because it overlooks the unpredictable nature of machinery and the potential for catastrophic failures if LOTO protocols are not diligently followed.
Employers can combat complacency by conducting regular refresher training sessions and fostering a serious workplace safety culture that emphasizes vigilance and strict adherence to LOTO protocols. Encouraging employees to report potential risks further helps maintain occupational safety standards.
Penalties for Lockout Tagout Violations
LOTO violations are classified into several categories, including serious, willful, and repeat offenses. A serious violation occurs when there is a substantial probability of death or serious physical harm, while willful violations indicate intentional disregard or indifference to LOTO safety standards. Repeat violations are issued for recurring offenses.
Violation Fines and Penalties:
- Serious Violations: Up to $16,131 per violation.
- Willful or Repeated Violations: Up to $161,323 per violation.
- Failure to Abate (Correct a Previously Cited Violation): $16,131 per day beyond the abatement deadline.
These penalties not only impose financial burdens on the company but also damage its reputation and can lead to increased scrutiny from the Occupational Safety and Health Administration.
Lockout Tagout Checklist
A lockout tagout checklist is an essential tool that guides the correct execution of all steps in the energy control process, reducing the risk of LOTO accidents during machinery maintenance and servicing. This checklist provides a clear sequence of actions that must be completed to safely de-energize, lock out, and tag out equipment. It also serves as a documented record that all necessary precautions have been taken.
Key Elements of a Lockout Tagout Checklist
- Identification of Energy Sources: Ensure all potentially hazardous energy sources, including electrical, mechanical, and others, are identified before beginning the LOTO process.
- Notification of Affected Employees: Inform all employees affected by the lockout/tagout process so they are aware that the equipment will be locked out and cannot be operated.
- Shutdown of Equipment: Properly shut down the equipment following standard operating procedures to prepare for the lockout/tagout process.
- Isolation of Energy Sources: Isolate all identified energy sources by disconnecting, closing, or releasing energy to prevent accidental re-energization.
- Application of Lockout Tagout Devices: Apply locks and tags to energy isolation points to secure them, with each worker using their own lock and tag for accountability.
- Release of Stored Energy: Safely release any residual or stored energy in the system to eliminate any remaining hazards before starting work.
- Verification of Isolation: Verify that all energy sources are completely isolated by testing the controls and using appropriate testing devices.
- Conduct the Necessary Work: Proceed with the maintenance or servicing tasks once isolation is confirmed and the work area is safe.
- Re-Energization Procedures: Carefully remove locks and tags, notify employees, and restore energy following the proper re-energization process after work is completed.
- Documentation and Recordkeeping: Document each step of the LOTO process, including dates, times, and personnel involved, to maintain a record for compliance and safety audits.
Lockout Tagout Procedure FAQs
How are lockout and tagout procedures enforced?
Lockout tagout procedures are enforced through regular safety audits, employee training, and adherence to OSHA regulations, which mandate that employers develop and implement a lockout tagout program that includes detailed energy control procedures and ensures compliance through inspections and corrective actions.
What are the hazards of lockout/tagout?
The hazards of lockout/tagout include the risk of severe injury or death from the unexpected release of hazardous energy if equipment is not properly isolated, locked, and tagged before maintenance or servicing.
What is a LOTO violation?
A LOTO violation occurs when an employer or employee fails to follow proper lockout tagout procedures, such as not properly isolating energy sources, neglecting to apply locks or tags, or failing to verify that the equipment is safely de-energized.
Is it illegal to remove a lockout tagout?
Yes, it is illegal to remove a lockout device unless you are the authorized employee who applied it, or you have followed the employer's approved procedure for removing the lockout device in the absence of the authorized employee.
What is the requirement for using a tag by itself on equipment that cannot be locked out?
When a tag is used by itself on equipment that cannot be locked out, OSHA requires that the tag must be supplemented with additional LOTO safety measures, such as isolating the equipment, removing an isolating circuit element, blocking a controlling switch, or opening an extra disconnecting device, to provide the same level of protection as a lock.