The numbers are staggering: Lockout-Tagout (LOTO) violations are consistently among OSHA's 10 most common violations every year. Without proper LOTO procedures, approximately three million workers are at risk every day, and compliance with OSHA's LOTO standard can prevent an estimated 120 fatalities and 50,000 injuries each year.
Fortunately, regulations and accepted best practices make it easy to establish an effective LOTO program that will save lives and create a culture of safety in facilities large and small.
This article will provide an overview of what's required of a LOTO program when LOTO must be used, and what work must be done to ensure a safe working environment.
The OSHA LOTO standard for general industry (29 CFR 1910.147) requires that employers establish a lockout-tagout program whenever workers are involved in servicing or maintaining machines that would expose them to hazardous energy in the event of unexpected energization or the release of stored energy. Each facility's LOTO program must protect employees from all sources of hazardous energy, ranging from electrical energy to hydraulic pressure, and even including gravity and heat.
The OSHA LOTO standard sets the minimum requirements that must be included in a facility's LOTO program. These requirements state that employers must:
OSHA requires the written procedures to include at least the following information:
Within the boundaries established by the OSHA standard, employers have the flexibility to develop custom procedures suitable for their situation and the types of machines they work with.
OSHA requires employers to develop and use written lockout tagout procedures describing what will be done to control hazardous energy. An employer's LOTO program should cover the following:
Broadly, the written LOTO program must answer the following questions:
Most de-energization procedures involve shutting down and "locking out" a machine to keep workers safe. This is done with a "lockout device," which physically holds an energy-isolation device in a safe or "off" position. The device physically locks into place such that no one can remove the device except the person who applied the device.
One example of a lockout device involves working on an electrically-powered machine. The source of energy is removed by opening a breaker, and the breaker is then locked into the "off" position using physical locks. Each person working on the machine places their lock on the breaker, and each person has the only key that will open their lock. This ensures that one person cannot remove all the locks while another person is still working on the machine.
Other types of locking devices may be applied to valves, steering wheels, switches, lock boxes, and pull-chains.
It may not always be physically possible to lock out an energy source. In these instances, a company's LOTO program will specify a tagout procedure, which uses visual communication (in lieu of a physical lock) to warn other employees against re-energizing a machine until it is safe to do so. In such situations, tags-featuring a prominent warning-are fastened to the energy-isolating device to warn about the dangers of re-energizing the machine while it is being serviced. Duralabel carries a variety of safety tags suitable for tagout situations.
Given that a tag is easier to defeat than a lock, it provides less protection. For instance, a tag may be accidentally removed, or an employee may remove a tag due to miscommunication. If tagout is used on a machine that can be locked out, the employer must ensure additional measures are in place to give workers the same level of protection that using a lockout device would have provided.
Before working on a machine, the following steps must be completed in sequence and according to the specific energy-control procedures established in the LOTO program:
If someone removes a lock or tag and re-energizes a machine while people are still working, someone may be seriously injured or killed. It is extremely important that only the person who applied a lock or tag remove that lock or tag.
The specific actions required to accomplish these steps should be in the LOTO program procedures for the machine or system. Generally, an employee should:
After all workers have removed their lockout or tagout devices, but before re-energizing the machine, everyone who works with the machine, as well as those in the area where the work on the machine was performed, must be informed that the LOTO devices have been removed and the machine is capable of being re-energized.
Employers should conduct periodic reviews of their LOTO program-at least once per year, per OSHA standards-to ensure employees are familiar with their responsibilities and that the specified energy-control procedures are being followed. The person doing the review must be an authorized person who is not involved with the LOTO procedure being reviewed. The review should determine the following:
For a lockout procedure, the periodic inspection must include a review of each authorized employee's responsibilities under the energy-control procedure being inspected.
For a tagout procedure, the review must also include all affected employees. Affected employees are those who are not involved in the maintenance or serving work, but who use or work with the machine, system or component being tagged out. Affected employees must be able to recognize tags and their meaning, know about tagout procedures and understand that tagged out devices must not be activated.
In addition, the employer is required to certify that the designated inspectors performed the required inspections. This certification must specify the following:
Labeling and signage can alert employees to electrical hazards and provide the necessary information in lockout/tagout situations. DuraLabel industrial label and sign printers by Duralabel can assist in developing custom visual communication. With several, tough-tested printers and more than 50 specialty label supplies, you'll find the right tools to help your employees remain safe.