OSHA’s standard for lockout tagout entitled, “The Control of Hazardous Energy,” is found on 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 regulations. Some states have their own enforcement of these rules. In order to keep this article brief, it will only refer to OSHA Lockout Tagout standards found in 1910.147.]
While 1910.147 does cover the requirements of any lockout tagout program for the General Industry, 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 lockout tagout needs around electrical equipment.
As a general practice, lockout tagout is a safe work practice 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. In this article, I will walk you through the process of creating and implementing an effective lockout tagout program.
Key Takeaways
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Lock out tag out programs are required when servicing or maintaining machines where hazardous energy could cause injury.
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A clearly written, machine-specific lockout tagout program ensures all energy sources are properly isolated, reducing the risk of unexpected re-energization.
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If equipment is modified, a lockout tagout written program must be updated so new energy sources or control points are properly identified and secured.
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If machines are updated or altered, the training program must be updated accordingly.
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To support the implementation of a lockout tagout program, comprehensive LOTO training must be provided, allowing employees to understand the procedures, safety risks, and compliance requirements.
Is a Lockout Tagout Program Always Required?
As far as OSHA inspectors are concerned, performing a task on parts of a machine that could move without first following lockout tagout procedures isn’t automatic grounds for a citation. The important things to keep in mind are 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 of injury if something activates unexpectedly, then lockout tagout 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 lockout tagout rules need not be followed. The exclusive control of the plug serves as an effective LOTO. However, plug lockout devices are available if there is a need for another layer of protection. Using plugs to avoid lockout tagout isn’t a way to circumvent the law, but in some instances, it can make sense to ensure the safety of all employees and provide additional layers of protection.
Hot tap operations may also fall in the same category where an alternative to a traditional lockout tagout program is not strictly required 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 and “tapping” directly into that line safely for a repair or adding a nozzle. If there is work being done on pressurized pipelines, then there are specially designed gate valve lockout devices as well. The gate valves are designed to prevent any stored energy from escaping the pipeline. However, stored energy, isolation, and hot taps are topics for another time.
How Do You Know the Machinery Is Locked Out?
While many normal production procedures will not need to follow the lockout tagout program, 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 lockout tagout. 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, which could include energy such as pneumatic, hydraulic, mechanical, stored or residual, or other types of energy from various sources.
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 energy is released and there is zero potential energy left in the system. There could be concerns about heat, pneumatics, or hydraulics having 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 lockout tagout becomes imperative. Using lockout tagout to eliminate the hazards is the best way to be certain that nothing can go wrong. Following lockout tagout to reach either a ZES or ZMS may require purging systems, sealing pipes, locking valves, installing blocks, and other measures.
Key Components of a Lockout Tagout Program
A general policy isn’t enough, there needs to be a specific plan for every piece of equipment that needs to be shut down. Below is the list of components of a lockout tagout program template:
1. Lockout Tagout Procedure
A full safety lockout tagout program will include documented energy control procedures. This list of tasks spells out the proper steps to lockout the machinery. Create written, step-by-step LOTO procedures for each machine, identifying all energy sources and shutdown steps. Use color-coded labels or diagrams to indicate isolation points for clarity. Ensure procedures are accessible near equipment and reviewed at least annually.
2. Lockout Tagout Devices
Standardize durable, unique locks and tags with employee names and contact details. Use keyed-different locks to prevent duplication and unauthorized access. Ensure devices are resistant to weather, chemicals, and tampering for long-term reliability.
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 procedures. Those repositories are the home of the company’s collection of padlocks, tags, blocking devices, and other safety hardware.
3. Training & Employee Responsibilities
Once employees have access to the equipment they need, the next step is teaching them how to use it. Provide hands-on LOTO training for all employees, focusing on their specific roles. Conduct annual refresher courses and document training records. Use real-life scenarios and drills to reinforce compliance and understanding.
4. Periodic Inspections & Audits
Perform annual LOTO inspections, led by qualified or designated individuals, ensuring compliance with written procedures. Interview employees to assess their understanding and correct execution of LOTO steps. Document findings, implement corrective actions, and retrain employees if needed. If you have the ability to trend findings of audits, give GM feedback to workers and improve training. Include workers in audits from time to time. Have a peer-to-peer audit program.
5. Communication & Coordination
Before maintenance, conduct pre-job safety meetings to communicate LOTO procedures to all affected employees. Clearly post LOTO notices or digital alerts in work areas to inform others. Coordinate with contractors and subcontractors, ensuring they follow site-specific LOTO requirements.
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 LOTO programs and procedures in an emergency situation as well as basic maintenance.
The relevant safety equipment, energy control procedures, and employee knowledge must be inspected regularly and annually at a minimum. Lockout tagout is meant to serve as a guarantee that a workplace is safe. That guarantee equipment is isolated and inoperable is only meaningful if all the parts of the lockout tagout program come together.
Why Is a Lockout Tagout Program Important?
Without a proper lockout tagout program, employees face risks such as electrocution, crushing, burns, amputations, and possible fatalities. Failure to implement control of hazardous energy accounts for nearly 10% of all serious industrial accidents. Furthermore, OSHA estimates that proper LOTO implementation prevents approximately 120 fatalities and 50,000 injuries each year in the United States alone.
These injuries not only result in significant human suffering but also impose financial burdens on companies through medical costs, legal liabilities, and lost productivity. A well-structured lockout tagout program fosters a culture of safety, ensuring workers are protected from hazardous energy and that maintenance operations are conducted efficiently without risk of unintentional machine startups.
Who Within the Lockout Tagout Program Can Place Locks and Tags on Equipment?
Only authorized employees are permitted to place locks and tags on securing lockout tagout equipment. This means, machine operators or other workers who interact with the equipment but do not perform maintenance, cannot apply or remove LOTO devices. When multiple authorized employees are involved or an authorized employee is absent, specific procedures must be followed to ensure safety and compliance.
Potential Failures Of a LOTO Program
One of the most common yet overlooked failures in a LOTO program is using generic procedures instead of machine-specific instructions. Not all equipment shuts down in the same way, and each machine has unique energy sources, shut-off points, and hazards. If employees follow a one-size-fits-all LOTO procedure, they may overlook hidden energy sources.
Now, even the best lock out tag out programs will fail if management does not enforce them consistently. Some workers may view LOTO as time-consuming and take shortcuts, believing that they can “get the job done faster” without properly locking out machinery. Others may ignore rules if they see that supervisors don’t take enforcement seriously. This leads to dangerous behaviors becoming normalized, increasing the risk of injuries and fatalities.
Training for Lockout Tagout
Training is mandatory for all employees, but not everyone needs the same level of knowledge. There are three different levels of lockout tagout training to give everyone the information they need without wasting time.
Every employee needs to be trained on lockout tagout, 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 on your policies and your program. Even machinery that is the same make and model in your facility could have different needs, there could be different add-ons or alterations that add steps to the lockout tagout 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 lockout tagout training 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 lockout tagout training needs to be recorded with the names of employees and the dates of training. Everything needs to be documented. Whenever training expires, everyone needs to be retrained.
How to Manage Lockout Tagout During Shift Changes?
The strict, rigid rules of a well-developed lockout tagout program 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 also multiple departments involved. When that is the case, each person will have their own lockout tagout 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 in a lockout tagout program 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 lockout tagout 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 for an efficient lockout tagout program 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 and 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 lockout tagout. Locks can easily be replaced, but lives can’t.
How Does OSHA Give Fines?
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.
The bottom line is–if your employees are held accountable by management and are trained effectively to do the right thing, and your leadership is conducting audits and giving feedback, everything will fall into place, and employees will go home safe!
Lockout Tagout Program FAQs
Who is responsible for the lockout program?
The employer is responsible for establishing and enforcing the Lockout Tagout (LOTO) program, ensuring compliance with OSHA standards. They must provide proper training, equipment, and enforcement of procedures.
Who is a qualified person for lockout tagout?
A qualified person for LOTO is an authorized employee who has received proper training to implement energy control procedures and safely lock out or tag out machines. This person must understand the specific hazards and control measures.
Who is required to have lockout tagout training?
All employees affected by or working around hazardous energy sources must receive LOTO training, including authorized employees (who perform LOTO), affected employees (who operate machines), and other employees (who may be in the area).
What is an affected employee's responsibility during a lockout tagout?
Affected employees must recognize when LOTO is in place, avoid interfering with locked-out equipment, and follow all safety protocols to prevent accidental startup. They should also communicate with authorized employees when necessary.
What type of employee does not participate in lockout tagout?
Other employees who do not operate, service, or maintain equipment are not directly involved in LOTO but must still be aware of procedures and avoid interfering with locked-out machinery.