About Lockout Tagout

Last year the US workplace experienced millions of recordable cases. Lockout tagout was the 6th highest violation handed out from OSHA. This is not a new trend building. Year over year companies are found to have problems with their lockout tagout programs.

What is Lockout Tagout?

OSHA’s standard for the control of hazardous energy, “requires employers to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees.” Simply put, this is just a formalized process for making sure your employees are protected from any harmful sources of energy during maintenance and servicing. Following written energy control procedures and placing locks on the isolation points serves to ensure that an easy and honest mistake does not result in serious injury or death.

Why is Lockout Tagout important?

Lockout Tagout has been the legally required in the United States for more than 30 years and best practice for even longer than that. At times it would seem redundant, inefficient, and contrary to common sense to have to place a lock on every isolation point for a piece of equipment being serviced, but in today’s modern era it is even more important. In a world where most equipment in the workplace has some form of computerized control, we are no longer looking to merely protect employees from other employees; we are looking to protect them from automated processes that could actuate at the wrong time.

NFPA 70E vs OSHA

NFPA’s 70E standard is one of the best resources for keeping employees safe from electrical hazards in the workplace. Among the requirements in the 70E standard you’ll find Lockout Tagout. Much like OSHA’s rules on LOTO, 70E requires a written program, written energy control procedures, and training. Where 70E greatly differs is that LOTO is a means of achieving electrically safe work condition and primarily focuses on electrical energy sources only. OSHA’s LOTO standard is more encompassing and calls out all forms of hazardous energy including electrical along with: hydraulic, pneumatic, mechanical, gravity, chemical, etc.

Written Programs​

OSHA’s Control of Hazardous Energy Standard requires employers to establish a written Lockout Tagout program to direct their operations safely through the LOTO process.

1910.147(c)(1)
Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

NFPA’s 70E Standard also requires employers to establish a LOTO program.

120.1 Lockout Tagout Program
(A) General. Each employer shall establish, document, and implement a lockout/tagout program. The lockout/tagout program shall specify lockout/tagout procedures to safeguard workers from exposure to electrical hazards…

While these standards require a written LOTO program they don’t necessarily give you the tools to make an effective LOTO program for your enterprise. Let us create a written program with you that will not only fit your regulatory requirements, but also be a useful and informative tool for your employees to remain safe in the workplace.

Energy Control Procedures​

One of the most important components of a well-crafted LOTO program are Energy Control Procedures. These ECP’s are meant to communicate to the employee, in no uncertain terms, how to effectively isolate and dissipate any hazardous energies within a piece of equipment with the purpose of making it safe to perform maintenance and servicing. OSHA provides greater guidance with respect to the content of ECP’s in their Control of Hazardous Energy Standard.

1910.147(c)(4)(i)
Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

1910.147(c)(4)(ii)
The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following:

1910.147(c)(4)(ii)(A)
A specific statement of the intended use of the procedure;

1910.147(c)(4)(ii)(B)
Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;

1910.147(c)(4)(ii)(C)
Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and

1910.147(c)(4)(ii)(D)
Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.

Our visual energy control procedures place all of these components neatly within a format that is easy for employees to understand and can clearly communicate every step of the process.

Training

Training is important in any topic of safety. It is how your program is concisely and effectively communicated to your employees. OSHA yet again requires employers to keep their employees trained on the subject of LOTO and how it affects them in the workplace.

1910.147(c)(7)(i)(A)
Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.

1910.147(c)(7)(i)(B)
Each affected employee shall be instructed in the purpose and use of the energy control procedure.

1910.147(c)(7)(i)(C)
All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out.

1910.147(c)(7)(iii)(A)
Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures.

1910.147(c)(7)(iii)(B)
Additional retraining shall also be conducted whenever a periodic inspection under paragraph (c)(6) of this section reveals, or whenever the employer has reason to believe that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.

1910.147(c)(7)(iii)(C)
The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary.

1910.147(c)(7)(iv)
The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee’s name and dates of training.

Generally employees are expected to sit through training once and be ready to handle the rigors of the workplace without fail – your training better be up to snuff! We pride ourselves on providing comprehensive and useful LOTO training that will stick with employees throughout their tenure in your organization.