By Barbara Semeniuk, 2020

Safety in the workplace takes proper training, planning, and implementation. With OSHA’s Lockout/Tagout program (LOTO), employers can stay up-to-date regarding safety measures for their employees who use industrial machinery and equipment. Consistency in a Lockout/Tagout program is vital, for both employers and employees to avoid serious injuries and citations.

For instance, there is a long-standing employee at an engineering firm with 30 years of experience in the control room. They are the only one who works with the machinery and know the specifics of how they work. If they leave or retire, someone from another department is hired to do the same work. The new employee doesn’t have any immediate references, and has to find old manuals to figure out equipment processes, potential hazards, and how to shut them down properly. Had there been an effective Lockout/Tagout program in place, there would have been an instructional guide put together by the previous employee.

Reviewing some initial questions about the Lockout/Tagout program:

Your Lockout/Tagout procedures should be a step-by-step program to prevent the accidental startup and release of energy from machinery and equipment. Once the equipment is no longer in use, it will be locked and tagged by the person in charge to ensure safe conditions.

Who should be trained on the Lockout/Tagout program? OSHA indicates that all authorized, affected, and other part-time and temporary employees should be trained on the Lockout/Tagout program. This includes those who regularly use the equipment, work nearby, and any temporary workers on site.

How often are inspections done for Lockout/Tagout procedures? Periodic inspections are conducted annually to ensure safety procedures are up to date. An employer may receive a citation under 1910.14v7(c)(6) under the Lockout/Tagout standard if the process is outdated.

The OSHA Defense Report emphasizes that a company’s Lockout/Tagout program needs to be descriptive and practiced consistently to be most effective. The article lays out five common mistakes companies make regarding the program.

Five common Lockout/Tagout (LOTO) mistakes:

  1. Confusion about when the Lockout/Tagout standard applies – The Lockout/Tagout standard applies when employees are exposed to an “unexpected energization.” When energy or operation is expected, an alarm sounds and lights flash, warning employees that the machine is in use and exerting power. However, when operation is unexpected, there is no warning, and a safety procedure must be applied.
  2. Missing or inadequate machine-specific procedures – Details are essential. The person(s) in charge of writing up the procedure needs to specify machine location, steps for proper startup and shutdown of the equipment, and identify when they are no longer using power. A team at a construction site, for example, is knowledgeable about their compactors and how they work. However, if an outside contractor is hired to do some additional work and needs to use the compactor, they may not be familiar with the particulars of the equipment model used by the team.

Without an instructional guide, it would be like someone trying to drive a manual car, when they’ve only used an automatic transmission. Failure to provide adequate and detailed procedures can lead to safety issues and a citation under 1910.147(c)(4) of the Lockout/Tagout program.

  1. Misunderstanding (or forgetting) periodic inspections – It is your responsibility to understand and implement a proper program. You can receive a citation for making mistakes or forgetting to conduct periodic inspections. The inspector and an authorized employee must review the procedure details, including implementation among employees. The employer reviews and corrects any deficiencies found during the inspection and receives a certification that lists the date, equipment inspected, employees involved, and the inspector’s name.
  2. Misapplying the Minor Servicing Exception – When minor services are implemented, such as clearing jams or minor tool changes and adjustments, the machine is not required to be locked or tagged out. This exception can easily be misapplied if the employee doesn’t understand the definition of “minor servicing.”
  3. Forgetting someone – It’s easy to remember to train “authorized” employees in charge of running the machines and equipment. However, training also must be provided to “affected” people working at the site near the device and “other” part-time and temporary employees. Any of these employees mentioned can be at risk if a malfunction occurs.

Once aware of the common mistakes companies make regarding the program, it’s important to review the Safety Management Group’s guidelines for implementing proper safety.

Eight steps for safer Lockout/Tagout programs:

  1. Detail the procedures for each piece of equipment – including location, detailed description of startup/shutdown, and list of all power sources
  2. Notify affected employees – before using the equipment, notify all employees that may be affected by the timing of the work
  3. Shut down equipment properly – the guide for proper shutdown should be detailed, including the order of actions
  4. Disconnect all power sources – after the equipment is fully shut down, all primary energy sources will need to be disconnected. Again, this needs to be a detailed procedure, specifying the location of power sources and connections
  5. Address secondary power sources – these may include any remaining pressure or energy sources such as heat or fumes that need venting
  6. Verify the lockout – once all power sources have been disconnected and the machine is out of use, test it by using the startup controls. Don’t forget to turn the equipment panels off before leaving to avoid an unexpected startup once it is reconnected again
  7. Keep the lockout in force during shift changes – once an employee has finished with the machine and is done with their shift, keep it locked for the next shift. Individual locks or tags will need to be replaced between each shift
  8. Bring the equipment back online – the process starts over again once the machine is ready for use. Make sure the equipment is clear of any tools before startup

Keep procedures up to date with periodic and annual inspections. As operating systems are developed and changed over time, make sure the program reflects those changes.

Company training can be done through the Lockout/Tagout Interactive Program, developed by the Directorate of Technical Support and Emergency Management. The interactive program goes through tutorials, discussions of hot topics and major issues, and interactive case studies. For more information on the Lockout/Tagout program, visit www.osha.gov or www.ccohs.ca/.

Sources

Conn, E. J., & Gelb, A. R. (2018, October 26). Unlock the Mysteries of OSHA’s Lockout/Tagout Rule (PART 2 of 2 – Five Common LOTO Mistakes),
https://oshadefensereport.com/2018/06/20/unlock-the-mysteries-of-oshas-lockout-tagout-rule-part-2-of-2-five-common-loto-mistakes/

Eight Steps for Safer Lockout/Tagout Programs. (2016, February 02),
https://safetymanagementgroup.com/eight-steps-for-safer-lockouttagout-programs/

Lockout-Tagout Interactive Training Program,
https://www.osha.gov/dts/osta/lototraining/index.html

Lockout Tagout Steps for Construction Sites,
https://www.grainger.com/know-how/safety/control-hazardous-energy-lockout-tagout-loto/kh-lockout-tagout-steps-construction-sites