
Key Takeaways
- Hazardous energy refers to any energy source that can cause harm if unexpectedly released, with ANSI B11.0 emphasizing task-specific classification as hazardous, non-hazardous, or beneficial.
- OSHA’s 29 CFR 1910.147 standard mandates lockout/tagout for hazardous energy control, and ANSI B11.0 supports alternative methods when justified through risk assessment.
- An effective hazardous energy control program integrates procedures, responsibilities, and training into daily operations, linking safety with stability, predictability, and productivity.
- Alternative methods, when applied using structured processes like TaBRA, allow necessary tasks to proceed safely without full energy isolation—aligning expert judgment with formal procedure.
What Is Hazardous Energy?
Hazardous energy is a term used to describe any source of energy that can be potentially dangerous to people if not properly controlled. This energy can exist in various forms, each capable of causing harm or damage when unexpectedly released or not properly isolated during maintenance and operational processes.
It is often stored energy ready to be released or is actively being transferred from one component to another. The inherent danger lies in the unexpected release of this energy, which can occur due to system failure, improper handling, or accidental activation of energy sources.
To effectively apply control of hazardous energy, it’s necessary to distinguish between hazardous, non-hazardous, and beneficial energy. According to ANSI B11.0-2023, Safety of Machinery:
- Hazardous energy is any energy that poses a risk of injury during a task.
- Non-hazardous energy is energy that does not expose personnel to harm during a task. For example, a low-voltage circuit used for diagnostics might be considered non-hazardous if it does not present an electrical shock or arc risk.
- Beneficial energy is energy required to reduce risk. It may be necessary to complete a task safely, such as maintaining control of coil tension or powering a Human Machine Interface (HMI) for troubleshooting.
Energy classification depends on the context of the task. As ANSI notes, energy considered non-hazardous in one situation may be hazardous in another. This task-specific view is the foundation of modern risk-based approaches like Task-Based Risk Assessment (TaBRA), which evaluates both the task and the energy involved before deciding on control measures.
Types of Hazardous Energy
There are several types of hazardous energy present in different industrial settings. These come in varying forms with different implications. Here is a closer look at the common types of hazardous energy.
Type of Hazardous Energy |
Definition |
Examples |
Electrical Energy |
Energy generated by the flow of electric charge; found in circuits, wiring, and electrical equipment. |
Live power lines, energized circuit panels, or charged capacitors in control systems. |
Mechanical Energy |
Energy in motion or stored in mechanical systems such as gears, springs, or rotating parts. |
Rotating flywheels, tensioned springs, conveyors, or machinery with moving parts. |
Pneumatic Energy |
Energy stored in compressed air or gases used in actuators, tools, or systems. |
Air compressors, pneumatic cylinders, or air brakes in manufacturing equipment. |
Hydraulic Energy |
Energy stored in pressurized liquids used in systems like lifts, jacks, or presses. |
Hydraulic presses, vehicle lift systems, or heavy equipment using hydraulic fluid. |
Gravitational Energy |
Potential energy held by elevated objects that can fall if released. |
Cranes holding suspended loads, storage racks, or elevated platforms. |
Thermal Energy |
Heat energy present in systems operating at high temperatures such as boilers or steam lines. |
Steam pipes, furnace systems, or molding machines operating at high heat. |
Chemical Energy |
Energy stored in chemical bonds, released during reactions involving fuels, batteries, or reactive substances. |
Battery systems, fuel storage tanks, or chemical mixing and processing equipment. |
Radiation Energy |
Energy emitted from electromagnetic waves, such as UV, X-rays, or gamma rays used in medical or industrial applications. |
X-ray machines, radiation therapy equipment, or industrial radiography tools. |
Dangers of Hazardous Energy

In August 2022, a fourth-year HVAC apprentice was fatally electrocuted while repairing equipment at a charter school in Kansas City, Missouri. The system had not been properly de-energized, and procedures to prevent unintentional startup were not followed. The worker came into contact with energized components during what should have been a routine task.
This incident illustrates a critical breakdown in basic safety protocols: assuming that equipment is safe to service without physically isolating energy sources. Across industries, uncontrolled hazardous energy continues to result in serious injuries, equipment damage, and operational disruption. The following are some of the most serious consequences of failing to control hazardous energy:
- Severe Physical Injuries: Injuries can range from electrocution, burns (from thermal or chemical energy), to trauma (from mechanical or gravitational energy), such as burns from steam leaks or crushing injuries from a mechanical press.
- Equipment and Property Damage: Improper management of hazardous energy can cause significant damage to machinery and property, such as machinery operating uncontrollably due to a sudden release of hydraulic energy, leading to equipment destruction.
- Fires and Explosions: Hazardous energy, particularly chemical and electrical, can trigger fires or explosions if unexpectedly released, threatening human life, causing property damage, and potentially harming the environment.
- Health Effects: Exposure to radiation or chemicals can lead to long-term issues such as cancer or organ damage. Incidents may also cause psychological effects like anxiety, PTSD, or depression, impacting a worker’s well-being and performance.
- Operational Disruption: Hazardous energy-related incidents can disrupt operations, leading to downtime, loss of production, and financial losses—all of which negatively impact company reputation and worker morale.
OSHA and ANSI Standards for Hazardous Energy Control
The Occupational Safety and Health Administration (OSHA) has established specific standards for controlling hazardous energy, often referred to as the Lockout/Tagout (LOTO) standards (29 CFR 1910.147). These standards provide guidelines for disabling machinery or equipment, thereby preventing the release of hazardous energy while employees perform maintenance and servicing activities.
In addition to OSHA’s regulatory framework, many safety professionals refer to ANSI B11.0-2023 for guidance on risk-based and task-specific approaches to energy control. The table below highlights key differences between OSHA’s compliance-driven requirements and ANSI’s performance-based recommendations:
Topic |
OSHA (29 CFR 1910.147) |
ANSI B11.0-2023 |
Definition of Hazardous Energy |
Energy capable of causing harm if released |
Allows task-based classification: hazardous, non-hazardous, or beneficial |
Primary Method of Control |
Lockout/Tagout required unless tagout is permitted |
Lockout/Tagout preferred; alternative methods allowed if risk is reduced and documented |
Risk Approach |
Prescriptive compliance |
Risk-based decisions through formal assessment |
Flexibility |
Limited to specific exceptions |
Broader use of methods when justified by task and risk analysis |
Use of Alternative Methods |
Permitted only under tightly defined conditions |
Supported if risk is reduced to acceptable levels through assessment |
While ANSI offers expanded flexibility for managing hazardous energy, OSHA’s standard remains the baseline legal requirement. Organizations must meet all OSHA requirements even when applying ANSI-aligned practices. The key components of the OSHA standard include:
- Energy Control Procedures: Employers must develop, document, and utilize hazardous energy control procedures for affixing appropriate lockout or tagout devices to energy-isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, startup, or release of stored energy.
- Employee Training: This involves instructing workers on the specific procedures and restrictions related to energy control measures relevant to their job assignments.
- Inspection: OSHA requires that periodic inspections of the energy control procedures be conducted at least annually to ensure that the procedures and the requirements of the standard are being followed.
- Energy Isolation: Clear identification and proper isolation of all relevant energy sources for machines or equipment involved in maintenance or servicing are crucial.
- Lockout/Tagout Devices: These LOTO devices must be durable, standardized, and substantial enough to prevent removal without excessive force or unusual techniques. Tagout devices must clearly indicate the identity of the employee applying the device.
Developing a Hazardous Energy Control Program
A well-built hazardous energy control program provides a structured system for identifying energy sources, defining control procedures, and assigning responsibilities during maintenance and servicing. The program serves as both a compliance framework and a practical tool for daily operations. Its effectiveness depends on clarity, consistency, and how well it's integrated into existing workflows.
Some safety programs fail because they are treated as separate from operations. But as veteran safety advisor Mike Taubitz explains: “Companies do not have to ‘balance’ safety and operational efficiency. When productivity and quality improve, so does safety.”
He further illustrates this by describing a scenario where equipment runs flawlessly with no unplanned maintenance or breakdowns. In that environment, there’s little need for workers to bypass safeguards or enter hazardous zones to restore production. Fewer disruptions mean fewer chances for exposure to uncontrolled hazardous energy.
This concept emphasizes that efficient operations and effective energy control go hand in hand. When systems are predictable, maintained, and stable, both safety and output improve together—not at each other’s expense.
The value of structured programs is also reflected in national data. According to OSHA, proper implementation of lockout tagout prevents an estimated 120 fatalities and 50,000 injuries each year. This reinforces that safety systems, when embedded in daily operations, protect both people and performance.
Hazardous Energy Control Policy
A written hazardous energy control policy is the backbone of any energy control program. It sets clear expectations for isolating hazardous energy during servicing, maintenance, and non-routine tasks. This policy must be formal, enforceable, and accessible to all relevant personnel. It must include the following:
Scope of Coverage
Defines which machines, systems, and energy types are included. Must cover all tasks where stored energy or unexpected startup can pose a risk, such as maintenance, cleaning, diagnostics, or setup.
Application Criteria
Specifies when lockout tagout must be applied. This includes specific triggers like opening a guard, entering a danger zone, or bypassing a normal production safeguard.
Roles and Permissions
- Identifies roles: authorized, affected, and other personnel
- Lists who can apply locks and tags, who verifies isolation, and who restores equipment to service
- Prevents miscommunication by making authority levels and responsibilities explicit
Required Procedures:
- Shutdown and Isolation Steps: The policy must outline how to shut down equipment, isolate all energy sources, and control stored energy. Generic guidance is not enough—steps must reflect the actual machines in use.
- Verification Requirements: Before work begins, workers must verify that energy is fully isolated. The policy should state acceptable verification methods, such as visual checks, testing instruments, or attempt-to-start procedures.
The policy should require periodic reviews—at least annually or immediately after an incident, near miss, or equipment change. Reviews ensure procedures reflect real conditions, not just what’s documented. An outdated policy poses just as much risk as no policy at all.
Training requirements should also be embedded in the policy. It should define when training occurs (e.g., initial, refresher, or change of assignment) and what each role must understand. Records of completed training should tie back to the policy as proof of implementation.
A robust hazardous energy control policy connects daily practices to broader safety objectives. When well-written and consistently enforced, it supports regulatory compliance, operational clarity, and worker protection in equal measure.
Control of Hazardous Energy: Roles and Responsibilities
A key element of an effective Hazardous Energy Control Program involves the clear definition of the roles and responsibilities of parties involved in the protocol, particularly the employer, supervisors, and workers.
Employer Responsibilities
Employers are responsible for developing and sustaining the entire hazardous energy control program. This includes writing procedures, selecting appropriate lockout tagout devices, ensuring training is delivered, and allocating time and resources for proper implementation. They must also assign clear authority for who can apply locks, verify isolation, and return equipment to service.
One of the most overlooked aspects of program effectiveness is how risk is identified. Mike Taubitz stresses the value of engaging frontline personnel directly:
“Engage operators, mechanics, and other service personnel using Task-Based Risk Assessment to identify situations where tasks are performed and the energy sources are then identified as hazardous, non-hazardous, or beneficial.”
This approach builds a more accurate and functional program by aligning control strategies with how tasks are actually done—not just how they’re documented. It also improves buy-in, since workers are more likely to follow procedures they helped shape.
Employers must also schedule regular audits and evaluations of the program. That includes reviewing training records, inspecting equipment-specific procedures, and tracking corrective actions after incidents or near-misses. Without these mechanisms, enforcement becomes inconsistent and risks go unaddressed.
Supervisor Responsibilities
Supervisors are responsible for applying the program in real time. They must verify that locks and tags are correctly applied, energy sources are properly isolated, and no step is skipped. This oversight is especially critical during high-pressure maintenance tasks or when schedules are tight.
Supervisors also act as safety enforcers and communication channels. They monitor compliance, provide coaching, and raise concerns when procedures don’t align with actual tasks. Their input is key to identifying procedural gaps or when a task may require a review of its hazard classification.
After any incident or deviation, supervisors are expected to lead immediate reporting, assist with root cause analysis, and recommend program updates. Their proximity to day-to-day operations gives them insight that higher-level management may miss.
Worker Responsibilities
Workers are the final line of defense between hazardous energy and injury. They must follow isolation steps exactly as written, use assigned lockout/tagout devices correctly, and never shortcut the process—even under pressure. Workers must also verify that stored energy has been released or controlled before beginning any task.
Training alone isn’t enough—workers need to feel confident in recognizing risks and empowered to speak up if something looks wrong. Their participation in safety meetings, job briefings, and program feedback loops ensures that procedures stay aligned with real-world conditions.
Reporting irregularities, unclear procedures, or equipment issues is a key part of a worker’s role. When workers are active participants—not just policy followers—the entire program becomes more effective, resilient, and grounded in reality.
Hazard Identification, Assessment, and Control
The process of hazard identification, assessment, and control is fundamental to the management of hazardous energy in the workplace. It involves a systematic approach to identifying all sources of hazardous energy, assessing the risks associated with these sources, and implementing appropriate controls to mitigate these risks.
Hazard Identification
Primarily involves conducting a comprehensive review of all equipment, machinery, and processes within the organization and understanding how equipment operates, the types of energy involved, and any potential sources of hazardous energy. For a more complete picture, this process also includes a review of previous incidents, near-misses, and maintenance records, as well as gathering valuable insights from employees.
Risk Assessment
Designed to evaluate potential risks associated with the potential release of stored energy. This should consider the magnitude of the energy, the likelihood of an uncontrolled release, and the potential consequences of such a release. Additionally, this step also assesses vulnerabilities in the existing safety system and prioritizes risks based on their potential impact and probability of occurrence.
Control Implementation
Focuses on developing measures to minimize or eliminate potential risks and exposure effectively. It utilizes a combination of engineering controls, administrative controls, and personal protective equipment (PPE) to enhance and ensure the safety of workers against the sudden release of hazardous energy.
Lockout Tagout and Control of Hazardous Energy

The Lockout Tagout (LOTO) procedure is a critical safety protocol aimed at preventing the accidental release of hazardous energy while equipment is being serviced or maintained. Effective LOTO procedures control hazardous energy and protect employees by ensuring that machines are properly shut down and cannot be restarted until the completion of maintenance or repair work.
Lockout Tagout follows a general 8-step LOTO procedure designed to effectively and efficiently address and prevent the release of stored hazardous energy:
- Preparation: Establish the need for maintenance/service, identifying all potential energy sources associated with the machine, and notify all personnel about the upcoming lockout procedure.
- Shut Down: Follow the established energy control procedure to shut down the machine or equipment. This often involves turning off power at control panels and may include additional steps specific to the equipment type.
- Isolation: Physically isolate the equipment from its energy sources by turning off breakers, closing valves, or disconnecting mechanical linkages.
- Lockout/Tagout: Apply lockout devices to energy-isolating fixtures like switches, valves, or breakers. Attach tagout devices with necessary information such as the reason for lockout, date of application, and the name of the authorized person who applied it.
- Stored Energy Check: Identify and mitigate all forms of residual or stored energy and ensure that these are either safely discharged or restrained before servicing.
- Verification: Verify that the equipment is properly isolated and de-energized by attempting to start it up (following a procedure that ensures no hazard is posed), check for stored energies, and use testing equipment to ensure all applicable hazardous energy sources are disconnected.
- Inspection: Confirm that all work is completed, tools and parts are removed, and the equipment is ready to return to service.
- Re-Energization: Remove LOTO devices only by the authorized individual who applied them or under their direct supervision. Carefully follow procedures to restore energy to the equipment, ensuring that no one is at risk during this process.
Lockout Tagout Devices
Choosing the right tools for lockout/tagout is crucial for ensuring that machines are securely isolated from their power sources during maintenance or repair. The choice for an energy isolating device should be made considering these key criteria:
- Durability: Devices must withstand the industrial environment where they are used. This includes resistance to corrosion, temperature extremes, and potentially abrasive or contaminating conditions.
- Standardization: To avoid confusion and ensure ease of use, devices should be standardized across the facility. This means using locks and tags that are uniform in color, shape, and size.
- Identifiability: Each lockout device should be clearly labeled with durable, non-fading tags that identify the user and provide space for additional necessary information such as the date of application and the purpose of lockout.
- Tamper-proof: Devices must be designed such that they cannot be removed without considerable effort or special tools, ensuring that only authorized personnel can remove them.
- Adaptability: Devices should be versatile enough to fit a variety of machinery and equipment, accommodating different sizes and types of energy isolation points.
Commonly used lockout tagout devices include:
- Lockout Tagout Padlocks: These are specialized padlocks designed specifically for LOTO purposes. Unlike standard padlocks, LOTO padlocks are uniquely keyed to ensure that only authorized personnel have access to the keys.
- LOTO Tags: These are durable, weather-resistant tags used to provide essential information about the lockout situation. These tags are typically made from materials that resist tears, water, and extreme temperatures.
- Electrical Lockout Devices: These devices are designed to physically prevent the manipulation of electrical controls like circuit breakers, push buttons, and switches.
- LOTO Kits: LOTO kits are comprehensive sets that include a variety of lockout devices and accessories, all contained in a portable case or bag. These kits are tailored to meet the needs of specific jobs or areas within a facility.
- Valve Lockouts: Valve lockouts are devices designed to cover the handles of valves, preventing them from being turned.
- LOTO Stations: LOTO stations are centralized locations where LOTO devices and information are stored. These stations are strategically placed around the workplace to ensure easy access to lockout devices.
Hazardous Energy Control Documentation
The last key component of an effective Hazardous Energy Control Program revolves around the extensive documentation of safety measures and procedures. This is critical to ensuring compliance with regulatory standards, facilitating training, and enhancing safety through transparency and accountability.
Energy Control Procedures
Each set of procedures should be tailored to specific types of equipment and operations. This includes step-by-step shutdown and restart procedures, identifying the appropriate lockout/tagout devices, and specifying the exact isolation points for each energy source. Ensure these documents are easily accessible to all relevant personnel.
Training Records
Employee training is an essential element of any safety program. To gain a better understanding of the impact of such training, record not only the dates and participants of training sessions but also the curriculum covered, the duration of the training, and the methods used. If applicable, include information on certifications earned by employees after completing the training, along with expiration dates of these certifications to track when refresher training is needed.
Inspection Reports
Document how frequently each piece of equipment is inspected and who is responsible for these inspections. Furthermore, use detailed checklists during inspections to standardize the process and ensure thoroughness. Checklists should cover all aspects of the equipment and its energy control procedures.
Incident Reports
Encourage and train employees to report incidents and near-misses immediately. Quick documentation ensures that details are accurate and that the response can be initiated promptly. Each report should include a thorough analysis to determine the root cause of the incident to aid in developing effective preventive and corrective actions.
Audit Records
Audits should result in detailed findings that are formally recorded. This includes any non-compliances, suggestions for improvement, and commendations for areas well managed. Document whether audits are conducted by internal staff or external experts. Each type offers different benefits and insights.
What to Do When Standard LOTO Isn't Enough?
While lockout tagout remains the most recognized method for isolating hazardous energy, there are tasks where applying standard LOTO is not practical or even possible. Some servicing or troubleshooting activities require energy to be present.
For example, when verifying system functions or conducting diagnostics. In these cases, simply locking out power could create new risks, disrupt critical operations, or prevent the task from being completed at all. In other cases, such as coil winders in metal processing plants, energy may be required to keep a roll of sheet steel safely contained. This would be considered beneficial or non-hazardous energy for tasks in the area, but not involving the coil winder.
Rather than forcing LOTO where it doesn’t fit, modern safety standards now support the use of alternative methods. These methods aim to reduce risk to an acceptable level using task-specific controls. The decision to use them must be based on a structured assessment—not convenience—so that safety is never compromised for the sake of access or speed.
Task-Based Risk Assessment (TaBRA)
Task-Based Risk Assessment (TaBRA) is a method used to evaluate hazardous energy risk based on the task being performed, not just the equipment or system involved. It aligns with ANSI B11.0-2023, which requires identifying tasks and hazards as part of the overall risk assessment process. TaBRA supports the use of alternative methods when standard lockout tagout procedures are not feasible.
Why Task-First Matters
ANSI B11.0, Clause 6.3, requires that reasonably foreseeable tasks and their associated hazards be identified. This includes normal operations, abnormal conditions, and failure scenarios. Without defining the task first, it’s impossible to accurately classify the energy or apply appropriate controls.
The same energy source can be hazardous during one task and non-hazardous or beneficial during another. For example, power may be needed for a control interface during diagnostics, but would be hazardous during mechanical repairs. TaBRA makes these distinctions task-specific.
Risk Is Not Binary
ANSI B11.0 explicitly states that “zero risk does not exist and cannot be attained.” The goal is to reduce risk to an acceptable level through feasible and practical measures. That level must be determined based on the combination of probability and severity of harm, not assumptions or blanket procedures.
The TaBRA Process
- Define the task: Document what is being done, how, and under what conditions.
- Identify energy sources: For each step, determine what energy is present and whether it poses harm during that specific task.
- Classify energy types: Label energy as hazardous, non-hazardous, or beneficial based on the actual exposure and role in the task.
- Assess the risk: Use a defined matrix (such as ANSI’s 4x4 model) to determine the risk level for each hazard.
- Apply feasible controls: Select risk reduction measures appropriate to the task, prioritizing those that are both effective and practicable.
Making Confident Decisions
Deciding whether a control method is sufficient can be a challenge, especially when departing from standard LOTO procedures. TaBRA helps teams make that decision based on documented task steps, actual exposure, and structured evaluation.
As Taubitz notes, “Following this methodology will provide teams with the competence and confidence to stand behind their determination of feasible risk mitigation.” That confidence comes from knowing the process is repeatable, practical, and based on how the work is actually done—not assumptions or guesswork.
Hazard Control Hierarchy
The hazard control hierarchy, as defined in ANSI B11.0, ranks methods of reducing exposure to hazardous energy. It guides teams to apply the most effective controls first, starting at the source of the hazard, rather than relying only on training or personal protective equipment.
Control Methods (in order of preference):
- Elimination: Remove the hazard entirely so it no longer exists during the task. Example: Using automated systems to avoid human entry into danger zones.
- Substitution: Replace the hazard with something less dangerous. Example: Using low-voltage tools instead of live high-voltage panels.
- Engineering Controls: Apply physical barriers or design changes to prevent exposure. Examples: Installing interlocks, fixed guards, or enclosed systems.
- Awareness Aids: Use signals or visuals to alert personnel to hazards. Examples: Warning lights, signage, or system status indicators.
- Administrative Controls: Reduce risk through procedures, scheduling, or training. Examples: Task-specific protocols and trained personnel requirements.
- Personal Protective Equipment (PPE): Provide equipment to reduce the severity of exposure. Examples: Arc-rated suits, gloves, or face shields.
Higher-tier controls offer stronger protection because they reduce reliance on behavior. Lower-tier controls require human action and are more likely to fail under pressure or distraction.
Not every risk control is feasible in every situation. As Taubitz explains, determining whether a risk reduction measure is practicable involves evaluating multiple factors:
- Regulatory obligations
- Introduction of new hazards
- Effectiveness
- Machine performance
- Usability
- Productivity
- Durability and maintainability
- Ergonomic impact
- Economic and technological feasibility
These considerations help teams apply the hierarchy in real settings—prioritizing the best available control while staying grounded in what the task and equipment truly require.
Control Reliability for Alternative Methods
When using alternative methods to control hazardous energy, the safeguards in place must meet a higher standard of reliability. This is especially important when energy is intentionally present during servicing or troubleshooting. In these cases, equipment design and safety systems must compensate for the absence of full isolation.
ANSI B11.0 defines control reliability as the ability of a safety-related control system to perform its intended function under fault conditions. This includes the detection of faults and ensuring that the system moves to a safe state. The purpose is to maintain protection even if part of the control system fails.
After risk assessment and selection of the appropriate risk reduction measure, employers should turn to ANSI B11.19-2019, Performance Requirements for Risk Reduction Measures: Safeguarding and other Means of Reducing Risk. OSHA has long referred both suppliers and users of equipment to B11.19, and this is a good place to clarify a common misconception. B11.19 is not used to select a risk reduction measure or safeguard; that is done in B11.0 or another machine-specific standard in the series of B11 general industry machine safety standards.
The foreword to B11.19 contains essential information, including, but not limited to:
This standard relies on other standards to determine which risk reduction measure(s) is required or allowed to control identified hazards/hazardous situations and is intended to be used in conjunction with the ANSI B11.0 standard on general safety requirements and risk assessments of machines, and any relevant ANSI B11 “base” standard for a given machine.
Throughout its history, ANSI B11.19 has not provided the requirements for the selection of the risk reduction measures, but only the implementation of the risk reduction measure once chosen.
This 2019 revision of ANSI B11.19 uses the more inclusive term “risk reduction measures” to replace the historical term “safeguarding” in most instances. Safeguarding includes guards, safeguarding devices, awareness devices, and safeguarding methods. Safeguarding is actually a subset of the more comprehensive term risk reduction measure. Although the term “safeguarding” has been used in the U.S. for decades, there has been some confusion as to its use and specific technical meaning, particularly considering globalization and with the attendant increasing international commerce and industry.
Alternative Methods required control reliability. Control reliability is not the same as general system reliability. It focuses on failure detection and response specifically for safety functions. For example, if a safety circuit fails, it must not allow unintended movement or re-energization of a hazardous system.
To meet this requirement, alternative methods often rely on a combination of components such as dual-channel safety circuits, monitoring relays, and fault-tolerant logic systems. These are typically validated through risk assessments and functional safety standards like ANSI B11.26-2024, Functional Safety: General Principles for Designing Safety-Related Parts of Control Systems for Machinery, ISO 13849, or IEC 62061. The safety-related parts must perform consistently, even during foreseeable hardware or software failures.
For alternative methods to be acceptable, the protective systems must be designed and maintained to this level of reliability. Anything less increases the risk of unintended energy exposure during servicing tasks. Control reliability, in this context, is what allows an alternative method to replace full lockout tagout without increasing overall risk.
Implementing Alternative Methods in Practice
Once alternative methods are selected through task-based assessment, their success depends on how they are applied. The following examples show how specific tasks are performed safely without full energy isolation.
- A technician accesses a powered HMI during diagnostics to monitor system status. Instead of a full lockout, energy is controlled using insulated tools, physical barriers, and access restrictions.
- An operator makes speed adjustments on a press while it runs in inch mode. Two-hand control, safe speed monitoring, and hold-to-run functions are used in place of full energy isolation.
- A mechanic threads material through a tensioned roller system where loss of tension would create a hazard. The method includes mechanical stops, monitored motion control, and restricted access while power remains on.
- A team tests safety interlocks during validation of a new machine. Power must remain active to observe system behavior, so temporary guards, override controls with monitored reset, and authorized personnel-only access are used to manage risk.
These are not exceptions—they are planned methods based on task-specific risk assessment and reliable safeguards. Applying them effectively depends not just on procedure, but on knowing when a full lockout is not the safest or most functional choice.
In an article published in the Professional Safety Journal, Taubitz and his co-author emphasized that “zero energy” is not equivalent to the control of hazardous energy, nor is it found in OSHA regulations or ANSI standards. They argue that overly rigid enforcement of “zero energy” concepts can lead to system inefficiencies and unintended safety risks, particularly when workers are forced to bypass procedures to keep operations running. Their findings support incorporating alternative methods earlier in the design process to achieve acceptable risk based on how work is actually performed.
In the words of Taubitz, “The issue with LOTO is not how but when. The when is not really complex but most easily understood by mechanics and experienced authorized workers. Zero risk mentality folks tend to deny the reality of the workplace that workers must confront. Alternative methods are the answer. The steps might seem complex, but are relatively easy and quick.”
Rather than assuming workers must choose between safety and functionality, Taubitz points to the value of recognizing task demands and applying energy controls accordingly. Structured methods like TaBRA give organizations a way to formalize that judgment into consistent procedures without disconnecting from how the work is actually performed.
FAQs
When are workers likely to be exposed to hazardous energy?
Workers are most likely to be exposed to hazardous energy during maintenance, repair, or cleaning operations, especially when safety protocols like Lockout/Tagout (LOTO) are not properly implemented. These exposures can occur in any setting where machinery, electrical installations, or heavy equipment are used, and the energy has not been adequately isolated or controlled.
What is the OSHA hazardous energy control program?
A hazardous energy control program, as defined by OSHA, involves procedures to prevent the release of hazardous energies—electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other forms—during service or maintenance activities. Central to OSHA's guidelines is the Lockout/Tagout (LOTO) standard (29 CFR 1910.147), which requires employers to implement energy control programs, including energy isolation and lockout/tagout procedures, to protect workers.
Which industry has its own standards for the control of hazardous energy?
The construction industry has its own specific standards for the control of hazardous energy, distinct from general industry standards. OSHA provides separate guidelines and regulations for construction due to the unique nature of construction sites and the types of hazards present, which often differ significantly from manufacturing or industrial settings.
What type of energy is the most hazardous?
Electrical energy is often considered the most hazardous form of energy due to its ubiquitous presence, potential for immediate severe injury or death, and the complexity of systems that can make isolation more challenging. Electrical shocks, arc flashes, and electrocution are common risks associated with electrical energy.
Who is at greatest risk from the release of hazardous energy?
Maintenance and repair personnel are at the greatest risk from the release of hazardous energy because they often work directly with machines and equipment that must be de-energized. Without proper lockout/tagout procedures, these workers are exposed to high risks of injuries from unexpected energization, start-up of machinery, or release of stored energy.