Posted February 19, 2021
Lockout/tagout (LOTO), or the control of hazardous energy, consistently remains one of OSHA’s Top 10 most frequently cited violations. Electricians, machine operators, and laborers are among the 3 million workers who service equipment routinely and face the greatest risk of injury. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation.
OSHA’s lockout/tagout standard (1910.147) requires the adoption and implementation of practices and procedures to shut down equipment, isolate it from its energy source(s), and prevent the release of potentially hazardous energy while maintenance and servicing activities are being performed.
The standard defines “energy source” as any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.
Three LOTO employee roles
OSHA identifies three roles for employees under the LOTO standard.
Authorized employees do the servicing, maintenance, and repair. They apply the locks or tags and follow the lockout/tagout procedures. Authorized employees need the most detailed training.
Affected employees operate or use a machine. When this machine is down for service or maintenance, the employee can’t run it so he or she is “affected” by the equipment being locked out.
Affected employees also work in areas where machines are being serviced under lockout/tagout. These employees also are affected by the lockout because the equipment can’t be used.
Affected employees don’t do any service or maintenance work. They must stay clear of the equipment during repairs. OSHA clarifies this in the definition of “authorized employee,” saying that: “an affected employee becomes an authorized employee when that employee’s duties include performing servicing or maintenance.”
If employers want machine operators or other affected employees to do any maintenance or repair work on a machine, those employees must be trained and equipped to follow lockout/tagout procedures as authorized employees.
Most employers have employees who do not operate machines or do any equipment service or maintenance work. These workers aren’t directly “affected” by a lockout, but they do need some instruction on lockout/tagout. The standard says: “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” on trying to start equipment that’s locked or tagged.
Three levels of LOTO training
The LOTO standard requires different levels of training for the three categories of employees:
- Authorized employees must receive training on 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.
- Affected employees must receive training on the purpose and use of the energy control procedure.
- Other employees (those whose work activities are or may be in an area where energy control procedures may be used) must be instructed about the procedure and about the prohibition relating to attempts to restart or reenergize machines or equipment that are locked out or tagged out.
Lockout/tagout training must be provided:
- initially, or prior to the employee performing service or maintenance on equipment or a system,
- as needed for employee proficiency, and
- when there are new or revised energy-control procedures.
There is no annual training requirement.
Employers must certify that lockout/tagout training took place is being kept up to date. The certification must include the employee’s name and the date(s) of training and/or retraining.
What are the LOTO procedures?
The energy control procedures will be different for each type of machine. LOTO procedures must include the following steps, to be followed in order:
- Prepare for shutdown. Review the equipment’s energy sources, identify energy-isolating devices, and make sure affected employees have been notified.
- Shutdown of machine or equipment. Follow the formal operating procedures to turn off the machine.
- Isolate the machine or equipment. Operate each energy-isolating device to stop the flow of energy to the machine.
- Apply LOTO devices. Apply a lock(s) to the energy-isolating device(s). If tagout has to be used, apply tags to the energy-isolating devices, and take any additional safety measures, as applicable.
- Release stored energy. For example, drain pressure from lines, insert blocks to keep elevated parts stable, etc.
- Verify isolation of equipment. Try to turn on the machine at its control panel, check the readings on pressure gauges, etc.
Whatever an employee’s role – authorized, affected, or other – they need to understand the reasons for lockout/tagout and know the established procedures.