The lockout/tagout standard (OSHA calls it “Control of Hazardous Energy”), found at 29 CFR 1910.147, was the fourth-most-commonly cited OSHA standard in 2019. It is one of OSHA’s persistent inspection priorities.
It’s important to protect your workers from amputations and other serious injuries that can arise from the unexpected startup and cycling of a machine or process, the unexpected energization of a machine, or the release of stored energy from a machine during servicing and maintenance operations.
Fortunately for employers, when you’re in compliance with the OSHA standard, your workers are probably safe—and if your workers are safe, you’re probably in compliance with the standard.
Still, there are things employers miss, and the lockout/tagout standard persistently makes the list of the five most frequently cited OSHA standards. Take a look at your lockout/tagout program and make sure that you’re not making one of these common—and commonly cited!—lockout/tagout compliance mistakes.
1. Failing to Have Equipment-Specific Lockout/Tagout Procedures
This requirement, found at 29 CFR 1910.147(c)(4), was the most commonly cited section of the lockout/tagout standard in 2019.
What’s required?
Machines, processes, or pieces of equipment that could create a hazard during servicing or maintenance if they start up or cycle unexpectedly, or release stored energy, must have a specific, written lockout/tagout procedure. The procedure must address how to control each type of hazardous energy associated with the machine, and enable a worker to safely lock out those power sources.
Employers sometimes keep a “generic” lockout/tagout procedure on file. That’s a violation—as Birdsboro Kosher Farms learned the hard way. The meat products manufacturer, had four different types of machines—but only one generic lockout/tagout procedure. The Occupational Safety and Health Review Commission (OSHRC) upheld a Willful citation against the facility.
2. Failing to Train Workers in Lockout/Tagout
This requirement, found at 1910.147(c)(7) was the second-most-cited section of the lockout/tagout standard in 2019.
What’s required?
Employers are required to train workers in the purpose and function of the lockout/tagout program, and to ensure that they have the knowledge and skills they need. Employees fall into three different categories for training:
- Authorized employees, who actually perform servicing and maintenance on locked-out equipment, must be able to recognize the types of hazardous energy sources that exist in the workplace, and know how to isolate and control them.
- Affected employees are the operators of machinery that is being serviced, or employees who work in an area where equipment is being serviced. They must understand lockout/tagout well enough to know not to interfere or place themselves in danger.
- All other employees. In a workplace where energy control procedures are used, all employees must have a basic understanding of lockout/tagout, and the importance of not attempting to restart or reenergize machinery that is locked/tagged out.
Mistakes employers make:
Employers may fail to provide training at all, or they may provide training that is too general. Choice Products USA LLC, a cookie dough manufacturer in Eau Clare, Wisconsin, was fined $404,045 for failing to properly train authorized and affected employees in lockout/tagout. Birdsboro Kosher Farms had provided only “general awareness training” to its authorized employees.
3. Failing to Conduct Periodic Inspections
This requirement, found in 1910.147(c)(6), was the third-most-cited section of the lockout/tagout standard in 2019.
What’s required?
For each energy control procedure that is used in your workplace, you must conduct an annual inspection of the procedure while it is being performed, is to identify any deviations from the procedure or inadequacies in the procedure. The inspector must be an authorized employee who is not part of the lockout/tagout being performed. As part of the inspection, the inspector must review each participating employee’s responsibilities with that employee.
Mistakes employers make:
When it appealed its citation for failing to perform periodic inspections, Birdsboro Kosher Farms tried to argue that its written lockout/tagout program had been updated within the previous year. According to the judge, Birdsboro misconstrued the standard as “requiring only a review of the written procedures.”
At Fuyao Glass America, the employer missed the required step of the inspector reviewing the procedure with each authorized employee.
4. Failing to Establish a Lockout/Tagout Program
This requirement, found in 1910.147(c)(1), was the fourth-most-cited section of the lockout/tagout standard in 2019.
What’s required?
You need a written program that covers your energy control procedures, training, and periodic inspections.
Mistakes employers make:
Employers may fail to create a written lockout/tagout program at all, or they may be missing specific elements of the program. Unlike other OSHA written programs, there is no requirement to review the written lockout/tagout program annually—but a periodic review of each written lockout/tagout procedure is required under another section.
5. Failing to Follow the Sequence of Lockout/Tagout
This requirement, found in 1910.147(d), was the fifth-most-cited section of the lockout/tagout standard in 2019.
What’s required?
Your written procedures for lockout/tagout must proceed stepwise through certain elements, including:
- Preparation for shutdown
- Specific shutdown procedures
- Application of energy isolating devices
- Application of locks or tags to energy isolating devices
- Procedures for release or restraint of stored energy
- Verification of isolation
- Release from lockout or tagout
- Removal of lockout/tagout devices
Workers must follow these steps whenever performing lockout/tagout operations.
Mistakes employers make:
Written procedures often fail to include one or more of the above steps, and sometimes employers fail to ensure that workers follow these steps. Fuyao Glass America was cited for multiple, repeated instances of failing to require works to follow the sequence—and slapped with a proposed penalty of almost $73,000.
6. Failing to Protect Workers During Group Lockout/Tagout Operations
The rules for group lockout/tagout, found in 1910.147(f)(3), sometimes trip employers up.
What’s required?
When more than one person is involved in a lockout/tagout operation, all employees must “affix a personal lockout or tagout device” to a group lockout device.
Mistakes employers make:
Employers sometimes fail to make it possible for workers to participate in group lockout/tagout. FabArc, a fabricated steel products manufacturer in Oxford, Alabama, was cited under this provision for failing to repair the disconnect for a piece of equipment that two employees were working on, which made it impossible for either of them to affix a lock.
7. Failing to Identify All Energy Sources And/or Failing to Lockout All Disconnect Sources
When an employer’s lockout/tagout procedures are not specific or detailed enough, the employer may be cited under one of several sections for failing to identify and neutralize all energy sources or disconnects.
What’s required?
“Energy sources,” according to 1910.147(b), include any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.
Mistakes employers make:
Sometimes employers, like Birdsboro Kosher Foods, fail to identify all energy sources. “By not addressing all sources of energy” at the facility, an administrative law judge wrote, Birdsboro’s lockout/tagout program “failed to provide enough information to permit employees to lock the machines out.”
8. Failure to Notify Other Employers
This requirement, found in 1910.147(f)(2), applies in multi-employer situations.
What’s required?
When outside employers, such as contractors, perform lockout/tagout activities at a worksite, both parties must inform each other of their respective lockout/tagout procedures.
Mistakes employers make:
Sometimes employers simply don’t let one another know what’s going on. Otis Elevator was cited for this after an employee was injured during elevator maintenance at a department store in Brookfield, Wisconsin.
9. Abusing the “Servicing and Tool Changes” Exception
Paragraph (a) of 1910.147 specifies when the lockout/tagout standard applies, but it includes an exception, at 1910.147(a)(2)(ii)(b), for minor tool changes and adjustments and other minor servicing activities.
What’s required?
The lockout/tagout standard applies to normal production operations if employees must bypass a guard or other safety device, or place any part of their body into a danger zone. There is an exception for minor tool changes that applies only if the activity:
- is minor;
- takes place during normal production;
- is routine, repetitive, and integral to production, and alternative methods (to lockout/tagout) are used to provide protection to the worker.
Mistakes employers make:
Some employers have made the mistake of trying to use this exception for servicing and maintenance activities that are not part of normal production operations. At other times, employers and OSHA have differed over what constitutes “routine, repetitive and integral” or what alternative measures provide “effective protection” as required by the exception.
10. Failing to Manage Shift Change
The rules for group lockout/tagout, found in 1910.147(f)(3), are a frequent pain point.
What’s required?
If there is a personnel change during lockout, employers must have specific procedures in place to ensure that there is an orderly transfer of locks and tags between off-going and oncoming employees.
Mistakes employers make:
Employers may fail to anticipate that a lockout/tagout operation could extend beyond a single shift. Or, workers may simply leave the equipment locked out of service at the end of a shift, creating confusion and leading to the unauthorized removal of locks or tags.