No matter how vigilant you might be when it comes to lockout tagout (LOTO) procedures in your workplace, it helps to occasionally keep every employee on the same page. All employees should be trained about the procedures and requirements of your lockout tagout policy regardless of their positions as required by 1910.332 and 1919.147(c). Lockout tagout training ensures that the staff is familiar with his or her LOTO roles and responsibilities.
Is LOTO Retraining Required?
Yes. While there is no need for annual training, retraining is required to reestablish the LOTO proficiency of an employee, as well as introduce revised or new control procedures and methods (OSHA 29 CFR 1910.147 (c) (7) (iii) (C)). The employer must issue a retraining certificate that has the employee’s name and the dates he or she has been retrained.
When Is Retraining Required?
Retraining is required in the following situations:
1. A job assignment change involving the use of different electrical lockout tagout procedures
If an authorized employee is moved from one department to another and it involved a changed job assignment, he or she must be retrained. This way, he or she will get to be knowledgeable about the new energy procedures he or she is required to do.
2. A change in processes, machines, or equipment that presents new hazards
Consequently, any change in equipment or machines will result in changed LOTO control procedures or job assignments, or both. Retraining bridges the gaps between the new equipment, how it will be used, and what LOTO procedures apply to it.
Even if two pieces of equipment are the same including type and model number, their energy control procedures might differ from one another. For instance, equipment 1 is connected to a power source within the same floor, while equipment 2 is connected to another power source. In such a case, the LOTO procedures for these pieces of equipment will be different from one another.
3. A change in the procedures on controlling energy
No matter how well trained an authorized person is, if a certain change in how energy is controlled is not relayed to him or her, accidents are more likely to happen. Whatever change it is in the procedures on energy control, even the slightest ones, must be relayed to him or her.
4. Any reason to believe that an employee needs more knowledge on the energy control procedures
Even though an employee might be performing the same LOTO procedures for quite a while, he or she can benefit from retraining, especially if you can offer new ways for him or her to more efficiently perform the job. Lockout tagout forms can guide him or her through his or her assignments.
5. An employee deviating from the established procedures
Lockout tagout procedures are there for everyone’s safety. So if you observe how an employee deliberately skips certain steps in the existing LOTO procedures on the machine assigned to him or her, he or she must be retrained.
Each workplace is unique. As such, employers must develop programs, procedures, inspections, and training that meet OSHA standards while addressing the specific needs of their workplaces. Some of the tools that can be used to implement LOTO programs include lockout tagout training video, certification, LOTO supplies and kits, and more. Ultimately, retraining must be conducted as required by OSHA.