LOTO Requirements

Is Your Lockout Procedure “Specific” Enough for OSHA? – A 5 Step Assessment

Date First Published on SafetySmart Compliance: May 16th, 2012
Topics: Electricity | Lockout Tagout |

People planning a lockout/tagout procedure for a facilityBy Glenn Demby – Just having a lockout procedure to control hazardous energy during machine service and maintenance isn’t enough. The OSHA lockout/tagout standard (Section 1910.147(c)(4)(ii)) says the procedure must be “clear and specific.” This isn’t just window dressing; lack of clarity and specificity is a frequent source of OSHA citations. Are you vulnerable to such a citation? Here are 5 things about your own procedure to check to find out.

What “Clearly and Specifically” Means

The LOTO standard doesn’t define “clearly and specifically.” But thanks to over 2 decades of enforcement and guidelines, we have a pretty good understanding of what OSHA looks for in evaluating if a lockout procedure measures up.

Basic Rule: The procedure must include at least the information contained in the model lockout procedure in Appendix A of the LOTO standard. Appendix A used to be a non-mandatory guideline; but in a 2008 case against GM, OSHRC (the OSHA Review Commission) ruled that it’s a minimum standard of the information employers must include in their own procedure to satisfy “clearly and specifically” [Secretary v. GM, OSHRC Nos. 91-2834E & 91-2950, Dec. 4, 2007].

5 Things to Check for in Your Lockout Procedure

So checking your own procedure against the Appendix A model is an excellent starting pointing for assessing if it’s clear and specific enough for OSHA.

1. Company/Equipment Name   Yes [  ] No [  ]

The lockout procedure should be entitled something like “LOCKOUT PROCEDURE FOR” either:

  • The name of the company if it’s a single procedure; or
  • The specific equipment if it establishes multiple procedures.

2. Purpose of Procedure   Yes [  ] No [  ]

Section 1910.147(c)(4)(ii)(A) to (D) of the standard lists 4 minimum elements all procedures must contain, including a specific statement of the procedure’s “intended use.”

Compliance Strategy: Make sure your procedure includes a “Purpose” provision based the one contained in the Model Procedure of Appendix, which says:

MODEL LANGUAGE

Purpose This procedure establishes the minimum requirements for the lockout of energy isolating devices whenever maintenance or servicing is done on machines or equipment. It shall be used to ensure that the machine or equipment is stopped, isolated from all potentially hazardous energy sources and locked out before employees perform any servicing or maintenance where the unexpected energization or start-up of the machine or equipment or release of stored energy could cause injury.

3. Compliance Statement   Yes [  ] No [  ]

Although it’s not referred to in the actual standard, Appendix A includes a statement requiring employees to comply with the procedure.

Compliance Strategy: Include a “Compliance” provision based on the Appendix A model and by all means make sure you fill in the blanks to describe actions taken to enforce the procedure against employees who commit violations.

MODEL LANGUAGE

Compliance All employees are required to comply with the restrictions and limitations imposed upon them during the use of lockout. Authorized employees are required to perform the lockout in accordance with this procedure. All employees, upon observing a machine or piece of equipment which is locked out to perform servicing or maintenance shall not attempt to start, energize, or use that machine or equipment.

The following steps shall be taken in the event of violations of any of the above requirements: [list]

4. Detailed Description of Lockout Sequence   Yes [  ] No [  ]

According to Section 1910.147(c)(4)(ii)(B) of the LOTO standard, a lockout procedure must include a list of the specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy. A 2008 OSHA Enforcement Directive instructs inspectors how to evaluate if a procedure meets the “clearly and specifically” requirement: The procedure must “provide enough detailed information and guidance for an authorized employee to understand how to safely and effectively” follow the shutdown procedure, it says.

Example: In the GM case mentioned above, the plant’s lockout procedure telling employees to follow “the normal stopping procedure” without explaining what that procedure was too generic to satisfy the “clearly and specifically” language.

Compliance Strategy: The model procedure in Appendix A sets out an 8-part shut-down procedure, including specific elements that the actual standard says a procedure must list, i.e., methods and responsibility for placement, removal and transfer of lockout and tagout devices, and testing to verify their effectiveness.  Make sure your own procedure includes at least the same elements and that you fill in the blanks for each step, including the individual(s) responsible for performing each step:

 

MODEL LANGUAGE

Sequence of Lockout

 (1) Notify all affected employees that servicing or maintenance is required on a machine or equipment and that the machine or equipment must be shut down and locked out to perform the servicing or maintenance. [List name(s)/job title(s) of affected employees and methods of notification:]

(2) The authorized employee shall refer to the company procedure to identify the type and magnitude of the energy that the machine or equipment utilizes, shall understand the hazards of the energy, and shall know the methods to control the energy. [List type(s) and magnitude(s) of energy, its hazards and the methods to control the energy:]

(3) If the machine or equipment is operating, shut it down by the normal stopping procedure (depress the stop button, open switch, close valve, etc.). [List type(s) and location(s) of machine or equipment operating controls:]

(4) De-activate the energy isolating device(s) so that the machine or equipment is isolated from the energy source(s). [List type(s) and location(s) of energy isolating devices:] (5) Lock out the energy isolating device(s) with assigned individual lock(s).

(6) Stored or residual energy (such as that in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc.) must be dissipated or restrained by methods such as grounding, repositioning, blocking, bleeding down, etc. [List type(s) of stored energy – methods to dissipate or restrain:] (7) Ensure that the equipment is disconnected from the energy source(s) by first checking that no personnel are exposed, then verify the isolation of the equipment by operating the push button or other normal operating control(s) or by testing to make certain the equipment will not operate. Caution: Return operating control(s) to neutral or “off” position after verifying the isolation of the equipment. [List method of verifying the isolation of the equipment:] (8) The machine or equipment is now locked out.

 

5. Detailed Description of Restoration to Service Sequence   Yes [  ] No [  ]

The final section of the Appendix A procedure is the procedure for restoring machines or equipment to service after maintenance and servicing has been performed.

MODEL LANGUAGE

Restoring Equipment to Service

When the servicing or maintenance is completed and the machine or equipment is ready to return to normal operating condition, the following steps shall be taken:

(1) Check the machine or equipment and the immediate area around the machine to ensure that nonessential items have been removed and that the machine or equipment components are operationally intact.

(2) Check the work area to ensure that all employees have been safely positioned or removed from the area.

(3) Verify that the controls are in neutral.

(4) Remove the lockout devices and reenergize the machine or equipment.

Note: The removal of some forms of blocking may require reenergization of the machine before safe removal.

(5) Notify affected employees that the servicing or maintenance is completed and the machine or equipment is ready for use.

Final Caveat

Remember that Appendix A is just a template outlining the required elements, not something you can use verbatim. In other words, you must fill in the blanks by describing your own specific methods and who’s responsible for carrying them out.

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