According to a recent report, lockout tagout violations substantially increased by 29% from 2022 to 2023, particularly within the manufacturing sector. This alarming rise in violations coincides with the Control of Hazardous Energy (COHE) (Lockout/Tagout) standard consistently ranking among the Top 10 Most Frequently Cited OSHA Violations.
This common violation that consistently puts COHE on OSHAs top 10 list, emphasizes how often these safety measures are overlooked across industries. That’s exactly why in this article, we will break down the importance of LOTO training, its key components, and how proper training can prevent these violations and protect workers.
Key Takeaways
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Lock out tag out training is essential for workplace safety, ensuring employees know how to properly lock out hazardous energy sources.
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OSHA LOTO training requirements mandate that employers provide training to employees involved in the maintenance and servicing of equipment.
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LOTO training goes beyond using locks and tags; it includes identifying energy sources, understanding risks, following procedures, and ensuring proper communication.
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Hands-on training with real equipment allows employees to actively engage, practice procedures, and build confidence in applying LOTO correctly in real-world situations.
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Trainers should consider and use adult learning practices for the most effective result.
What Is LOTO Training?
Lock out tag out training is a safety energy control program designed to educate employees on how to properly control potentially hazardous energy sources when servicing or maintaining machines and equipment. The Occupational Safety and Health Administration (OSHA) sets the training requirements for lockout tagout (LOTO) under 29 CFR 1910.147. This standard requires employers to provide training that ensures employees understand the purpose and function of LOTO procedures, as well as how to apply these lockout tagout devices correctly.
Without proper training, employees may unknowingly expose themselves or others to serious risks, including electrical shocks, burns, crushing injuries, amputations, and even fatalities. On the other hand, proper employee training helps prevent these common but dangerous errors:
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Incomplete energy isolation
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Miscommunication among employees
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Unauthorized removal of LOTO devices
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Failing to verify de-energization before maintenance
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From my experience, companies that invest in lockout tagout training not only help prevent accidents but also avoid OSHA violations, costly downtime, and potential legal liabilities. When employees are properly trained, they know how to follow the right steps, communicate effectively, prevent accidents and contribute to a safety culture where each employee goes home safe and injuries are prevented.
Who Needs a Lock Out Tag Out Training?
Employees who work with or around machines that require maintenance need to undergo a lock out tag out training. OSHA has categorized these employees into three groups, each with specific training requirements:
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Authorized employees: These workers perform the maintenance and service tasks, and need full lockout tagout certification and hands-on quality training. They are in effect “authorized” by the company through training to perform LOTO.
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Affected employees: These are machine operators who are not involved in servicing or maintenance, and need awareness training so they don’t accidentally restart locked-out equipment. They are truly “affected” by the LOTO activity in that their machine or work area is affected.
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Other employees: Even those not directly working with equipment should understand lock out tag out safety training to avoid unintentionally interfering with procedures. At a minimum, these employees should be trained to an awareness level. For example, understanding that LOTO tags and signs are to be taken seriously and heeded.
Key Components of LOTO Training
Lockout tagout training is sometimes oversimplified as just putting a lock on a switch, which can lead to serious accidents. For example, a worker at my previous company properly locked out the power switch on a hydraulic press but failed to release the stored hydraulic pressure. When another worker accidentally pressed the foot pedal, the press activated and crushed the maintenance worker's hand.
Effective training must go beyond the basics to prevent these kinds of mistakes and keep workers safe. A comprehensive LOTO training program should encompass the following components:
Understanding Roles and Responsibilities
This component involves defining who is responsible for locking out and tagging out equipment, who can authorize or oversee the process, and who must be trained in energy control procedures. Authorized and Affected employees need to understand their duties in implementing and following LOTO protocols.
Unclear roles and responsibilities can cause confusion, leading to miscommunication and missed steps. This increases the risk of accidents as employees and management are unsure of their specific duties.
Identifying Hazardous Energy Sources
Employees must recognize all potential energy sources within the workplace, including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other sources of potential energy. This involves inspecting equipment and reviewing documentation to locate energy sources that could pose risks. This can be done through a COHE assessment.
Similar to the accident I described earlier, a common mistake is failing to recognize hidden or secondary energy sources. Stored energy in capacitors, pressure buildup, residual mechanical energy, or fluid/liquid in a system that may be present but undetected, can still cause injury if not properly identified and controlled.
Learning the Type and Amount of Energy in the Workplace
Each machine or system operates using different types and levels of energy. Both authorized and affected employees must know how much energy is present and how it behaves when shut down. This information is typically found in equipment manuals, energy control procedures, or past incident reports.
Misjudging energy levels can result in incomplete lockout procedures. If employees underestimate stored energy or do not wait long enough for it to dissipate, they risk serious injury when maintenance begins.
Using LOTO Devices Correctly
The image above shows that LOTO devices, including locks and tags, must be used according to established procedures. This means selecting the right lockout device for each energy source, applying it correctly, testing the device and its proper application, and making sure it remains secure throughout the maintenance or servicing task.
Using non-OSHA-compliant lockout tagout devices can render the procedure ineffective. If a device does not fully prevent energy release or is not durable enough to withstand environmental conditions, it can fail, leading to hazardous situations.
Isolating and Controlling Energy
This step involves shutting down equipment, disconnecting energy sources, and applying the appropriate lockout devices. Verification procedures must be followed to confirm that all energy has been removed before work begins. Failure to follow the correct sequence when isolating energy can lead to incomplete shutdowns.
Some authorized employees may assume that flipping a switch is enough, without realizing that additional steps, such as bleeding pressure from a hydraulic system or “trying” an on/off switch are necessary. This step is more commonly known as verification of isolation.
Preventing Tampering with LOTO Devices
LOTO devices must remain in place without unauthorized removal or interference. This requires strict enforcement of policies, clear labeling, and disciplinary measures for violations. Employees must understand the consequences of removing or bypassing these devices without proper authorization.
Unauthorized removal of locks and tags, whether due to impatience, lack of awareness, or disregard for safety rules, can lead to unexpected equipment activation. Without proper enforcement and accountability, workers may not take LOTO procedures seriously.
Avoiding Accidental Restarts
Before any work is completed, verification steps must be taken to confirm that no one is in danger before the equipment is restarted. Employees need to follow communication protocols, inspect the work area, and remove all tools and personnel before releasing locks and tags. Some best practices include a restart checklist by a peer or another employee.
Restarting equipment while workers are still in hazardous areas is a major risk. This often happens when communication breaks down or when employees fail to verify that all LOTO devices have been removed by authorized personnel only.
How Often Should Employees Be Retrained?
A one-time lock out tag out training session is not enough. OSHA requires periodic retraining, especially if:
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An employee changes jobs and works with new equipment.
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A workplace incident suggests LOTO procedures aren’t being followed.
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Equipment or energy control procedures change.
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Regular audits reveal gaps in understanding.
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Or in the event there is an incident which requires retraining.
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Most companies I’ve worked with conduct refresher lock out tag out safety training at least once a year—but more often, hands-on, instructor-led training is most effective.
Best Practices for Effective LOTO Training
I often talk with colleagues in my field about what makes LOTO training both engaging and effective. Based on those conversations and my own experience, here’s what I’ve found works best:
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Implement a comprehensive written LOTO program: Employees need access to clear, detailed procedures that outline how to properly shut down, lock out, and restart machinery safely. Ensure your training is following the procedure requirements and meets OSHA standards.
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Train employees on different energy sources and their hazards: Many workplace accidents happen because employees only think about electrical power, while other energy sources such as hydraulic pressure, compressed air, or mechanical tension remain unaddressed.
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Conduct hands-on training with real equipment: Instead of repeating the same PowerPoint slides, include hands-on lockout drills, role-playing scenarios, and real-world case studies to keep employees engaged. Ask a maintenance or machine expert to help conduct or lead the training
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Conduct regular audits and assessments: Regular LOTO audits help identify gaps in understanding, catch unsafe habits, and reinforce training where needed. Include a Supervisor or a peer in these audits.
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Build a strong safety culture around LOTO: Even with proper training, workplace safety attitudes can make or break a lock out tag out program. Employees need to feel comfortable reporting unsafe behavior and holding each other accountable for following LOTO rules.
Lock Out Tag Out Training Material
Lock out tag out training materials come in various formats to accommodate different learning styles and workplace needs. Safety posters and infographics serve as constant visual reminders in the workplace, displaying key LOTO steps, proper lockout device usage, and hazard awareness. This material makes it easier for employees to recall essential information during their daily tasks.
Now, many safety experts recognize online training as a convenient and scalable way to educate employees, especially for large organizations. Online training courses allow employees to learn at their own pace through interactive lessons, quizzes, and case studies to test knowledge and reinforce key concepts. Employees can receive a lockout tagout certification after completing these online training courses.
Meanwhile, VR training is gaining popularity for its interactive and immersive learning experience without real-world risks. Many experts believe that simulating hazardous situations in a controlled virtual environment helps workers develop muscle memory and decision-making skills before applying procedures in real life.
Remember adults learn by exercises, their experiences, telling stories and actually conducting the tasks. Training should be memorable, and well thought out and should include leaders in the workforce to help communicate effective key points.
Lock Out Tag Out Training FAQs
How often should LOTO training be required?
LOTO training should be provided initially when an employee starts a job that involves servicing or maintaining equipment and should be repeated periodically. OSHA requires to retrain employees whenever there is a change in job assignments, equipment, or procedures, or if an audit reveals gaps in understanding.
What is the objective of LOTO training?
The goal of lock out tag out training is to teach employees how to safely isolate hazardous energy sources to prevent accidental machine start-ups and unexpected energy releases. It ensures workers understand OSHA lockout tagout procedures and how to apply them correctly in real-world situations.
How long does LOTO training last?
The duration of LOTO training depends on the complexity of the workplace and equipment but typically ranges from 1 to 4 hours for a basic session. More detailed training, including hands-on practice and advanced procedures, may take a full day. Maybe longer for machine- or equipment-specific training.
Does LOTO training expire?
LOTO training does not have a fixed expiration date, but OSHA requires refresher training if an employee fails to follow procedures, new equipment is introduced, or an inspection identifies safety concerns. Many companies choose to conduct annual refresher courses to keep workers updated.
How long is LOTO certification good for?
Lockout tagout certification remains valid as long as the employee follows proper procedures and no retraining is required due to safety violations or job changes. Many employers renew lockout tagout certification every one to three years to reinforce safety practices and compliance.