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Occupational Safety and Health Administration (OSHA) compliance isn’t just about ticking boxes—it’s about creating a workplace where occupational safety comes first. By following OSHA regulations specific to your business and investing in compliance training, you’re building a culture of protection and preparedness.
The result? A workplace where serious hazards are minimized, employees feel secure, and everyone can focus on what they do best without unnecessary risks and workplace injuries.
OSHA Standards for Lockout Tagout
For OSHA and OSH Act compliance, Lockout Tagout falls under OSHA's 1910.147 Standard, titled "The Control of Hazardous Energy". Whilst having energy control procedures in place is a OSHA requirement, this standard is a "performance standard", meaning that an obligation is placed on the site to determine the best method of implementing a LOTO program. There is no "one size fits all" approach to implementing a LOTO program for each workplace.
OSHA Standards also require employee training on lockout tagout, but this is not defined by a defined period of time but by the level of competency of the organization's employees. The level of competency can be determined based on the frequency with which the employee performs LOTO.
What is hazardous energy?
Machine elements operate on powerful energy sources like electrical, hydraulic, mechanical, chemical and thermal, which can be deadly to workers. Sudden startup or energy releases during maintenance can lead to catastrophic injuries or even death.
Effective hazardous energy control is essential to ensure a safe working environment and injury prevention.
What are the potential effects of hazardous energy?
Workers face life-threatening health risks like electrocution, burns, and amputations when hazardous energy isn’t properly controlled during machinery maintenance. Some harrowing examples of these incidents in industry include:
- An employee scraping off dough from a hopper at a snack foods manufacturer when the machine turned on and cut off part of his finger.
- A 52-year-old worker was fatally injured when a shredder's hydraulic door suddenly closed and activated while he was clearing a jam, with the system's hazardous energy sources still active, and the machine not rendered inoperative.
- A 36-year-old man died at an Iowa pork plant when an auger conveyor started unexpectedly. While retrieving fallen hardware, his feet became entangled. A supervisor, unaware of his presence, reactivated the electrical circuit breaker, causing the auger to start.
These real-life incidents where regulation has been ignored, highlight the daily dangers faced by craft workers, electricians, machine operators, and laborers. Proper hazardous energy control is a life-saving necessity, not just an OSHA requirement.
How can you control hazardous energy?
Embracing LOTO a site must establish a strong Hazard Communication Plan (HCP). Mastering the 9 steps of LOTOTO is key to achieving OSHA compliance for your Lockout Tagout program.
Step 1: Prepare
The responsible individual ensures safety by reviewing work orders, conducting pre-job briefings, inspecting machinery, verifying lockout procedures, and following Safe Working Practices. They also complete required permits and documentation for safe, efficient job execution. Putting an emergency action plan in place can also fit under this step if deemed appropriate.
Step 2: Notify
The responsible individual notifies all affected employees through appropriate methods such as the control room, radio, or physical entry to the area. They inform everyone that the equipment will be isolated, advise them to stay clear, and instruct them not to operate the machinery during the isolation.
Step 3: Turn off equipment
Follow the manufacturer's shutdown procedure to safely deactivate equipment, ensuring all energy sources, including residual ones like air or hydraulic pressure, are fully de-energized. Secure moving parts and address all potential hazards.
Step 4: Isolation
Personnel should, if safe, run the equipment before isolation to check for electrical defects that could affect the process. Use energy isolating devices, not operating controls, for isolation—avoid the STOP or EMERGENCY STOP buttons.
Ensure physical barriers are locked, and isolate all energy sources, including hydraulic and pneumatic. If panels have windows, confirm that contactors are separated.
Step 5: Apply Locks and Tags
Each energy isolation device must have a personal lock and tag applied, with each worker using their own lock and key to ensure security. Never lock out for others, and confirm isolation cannot be bypassed. If locking out isn’t possible, use alternative methods like fuses in lockboxes, disconnecting air pipes, blocking switches, or bleeding lines.
Address issues with an action plan, assess non-standard equipment with a supervisor and ensure only authorized employees remove tags, which must never be bypassed or ignored.
Step 6: ZERO ENERGY STATE
Hazardous energy must be fully relieved and made safe.
If stored energy remains a hazard to workers servicing the equipment or machinery, additional safety procedures, such as using chains, should be developed to dissipate or restrain it. Ensure these measures are effective, verify they work, and prevent hazardous energy from re-accumulating (e.g in air systems).
A good example of something else to check is to ensure conveyors are equipped with backstops to prevent rollback. Remember, gravitational energy is potentially a hazardous source of energy.
Step 7: Try-out
Before starting, test equipment controls to ensure it is de-energized and won’t operate. For systems with multiple start sources, confirm isolation with electrical support if needed. Be cautious with automated systems prone to unexpected energizing. If equipment operates during testing, shut it down, notify a supervisor, report a near-hit, and investigate. Always test before touching to confirm effective isolation.
Step 8: Perform Task
Complete the task following the risk assessment and safe working practices.
If stored or other energy is suspected to be energized or unsafe, stop the task immediately, withdraw all personnel, implement control measures, report a near-miss, and conduct an investigation into how to control hazardous energy to ensure worker safety. The site's energy control procedures should also be reviewed as part of this process.
Step 9: Inspect and Restore machines or equipment
The responsible person must inspect the area for safety, confirm all guarding is secure, and notify everyone that power will be restored. Remove only personal lockout devices, restore equipment, verify proper operation, and notify supervisors or production. Complete required paperwork, perform test runs if needed, and transfer equipment back to production. If the equipment doesn’t restart, reapply locks and investigate.
Elements for a successful Lockout tagout program?
OSHA-compliant Lockout Tagout procedures prevent 120 fatalities and 50,000 injuries annually, underscoring the importance of controlling hazardous energy. Employers must provide durable, standardized lockout devices and conduct regular training to ensure proper procedures are followed, as outlined in OSHA's Lockout Tagout Standard.
1 - Develop a LOTO Program
The foundation of a successful lockout/tagout program begins with a well-documented and clear energy control policy. A written Control of Hazardous Energy (LOTO) program not only defines the essential elements of your safety plan but also provides a roadmap for implementation.
While OSHA guidelines set the baseline, tailoring the program to meet the specific needs of your workers ensures it’s practical and easy to follow in their daily tasks. This isn’t a "set it and forget it" process—a lockout program should be reviewed annually to stay relevant and maintain its effectiveness in protecting workers on your team.
Building a robust lockout program is a collaborative effort, bringing together insights and expertise from every level of the organization to create a culture of safety and accountability.
2 - Write Specific Machine LOTO Procedures
Lockout Tagout procedures should be more than a checklist; they must provide clear, detailed steps for safely shutting down, isolating, and securing machines or equipment, including lockout/tagout device handling.
To go beyond OSHA compliance, create best-practice procedures with machine-specific photos that identify isolation points, and post them where workers can easily see. This ensures a safer, more effective process for maintenance staff.
3 - Ensure Isolation Points are Visible
Mark all energy control points—valves, switches, breakers, and plugs—with permanent, standardized labels or tags that align with your equipment-specific procedures. Consistency is key for safety and clarity!
4 - Periodic Inspections, Training and Audits
Train your workers thoroughly, communicate processes clearly, and conduct regular inspections to keep your program effective. Go beyond OSHA requirements by incorporating your machine-specific procedure practice.
OSHA evaluates lockout/tagout compliance by checking training for:
- Authorized employees performing lockout procedures.
- Affected employees using machinery under maintenance.
- Other employees working near machinery being serviced.
Proper training ensures everyone understands their role in maintaining a safe environment.
5 - Install the Correct Lockout Tagout Devices
With countless safety products available, choosing the right ones for your specific application is crucial to effective lockout. The right device ensures both safety and efficiency. Once you’ve made your selection, document and consistently use devices tailored to each lockout point for maximum protection.
6 - Continually Review the LOTO Program
A strong lockout tagout program consisting of continuous improvement through regular reviews often thrives. This proactive approach builds a safety culture, saves time, and prevents the costly cycle of recreating programs annually.
Sustainable programs not only reduce long-term expenses but also keep your company ahead, enhancing safety and efficiency year-round.
Summary
In summary, being compliant with OSHA's Lockout Tagout policy is incredibly important when controlling hazardous energy to prevent injury. Employers must provide durable, standardized, and easily identifiable lockout devices that cannot be reused.
To maintain compliance, employers should conduct regular LOTO training for maintenance staff and ensure thorough procedures are in place to address all energy sources.
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