How to Determine Which Operations Require LOTO

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Lockout Tagout | Machine Guarding |

The OSHA Control of Hazardous Energy (or Lockout/Tagout) standard, 29 CFR 1910.147, requires the implementation of energy isolation procedures when performing certain kinds of service, repair or maintenance operations on energized machinery and equipment. The first step in complying with the standard is to identify which, if any, service, repair or maintenance operations are actually covered by the LOTO rules. Here’s how.

What LOTO Does and Doesn’t Cover

The general rule: LOTO doesn’t cover normal production operations involving machines or equipment. It’s only when machines and equipment are maintained or serviced that the LOTO requirements kick in. For LOTO to apply:

  • Machines or equipment must be undergoing non-routine servicing or maintenance—as opposed to routine, repetitive and minor service activities that are integral to normal production operations,
  • Machines or equipment must be undergoing routine, repetitive or minor maintenance/servicing integral for normal production operations that: i. requires a worker to remove or bypass a guard or other safety device; ii. requires a worker to place any part of his body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation); or iii. involves an associated danger zone during a machine operating cycle.

There must also be a risk of unexpected startup, energization or hazardous energy release during servicing or maintenance, including while constructing, installing, setting up, adjusting, inspecting, modifying and maintaining and/or servicing machines or equipment. Examples:

  • Lubrication;
  • Cleaning;
  • Unjamming;
  • Adjustments; and
  • Tool changes.

The OSHA standard also list specific operations not covered by LOTO, including:

  • Routine, repetitive and minor service activities that are integral to normal production operations, e.g., minor tool changes and adjustments, for which alternative safety measures are in place;
  • Work on cord and plug connected electric equipment in which energization hazards are controlled by unplugging the equipment from the energy source and keeping the plug under the exclusive control of the employee performing the servicing or maintenance;
  • Hot tap operations involving transmission or distribution systems for substances such as gas, steam, water or petroleum products where the employer can show that: i. continuity of service is essential; ii. shutting down the system is “impractical”; and, iii. documented procedures and special equipment are used to effectively protect employees;
  • Installations under the exclusive control of electric utilities for the purpose of power generation, transmission and distribution, including related equipment for communication or metering;
  • Oil and gas well drilling and servicing.

Conclusion

The following Table summarizes the rules that determine if machinery/equipment servicing, repair or maintenance operations are covered by the LOTO standard:

OPERATIONS COVERED BY LOTO OPERATIONS NOT COVERED BY LOTO
Non-repetitive or routine maintenance or servicingOperations that involve removal of guards or disabling of safety devicesOperations in which workers must place body parts into danger zonesClearing a jammed or block machineRebuilding equipment

Equipment set up

 

Minor, repetitive or routine tool changesMinor, repetitive or routine adjustmentsMinor, repetitive or routine servicing integral to normal production activity and for which safeguards are in placeWork on unplugged electrical equipment or machines where the worker performing service or maintenance has exclusive control over plugHot tap operations on transmission and distribution systems for gas, steam, water or petroleum products where employer can show:

  • Continuity of service is essential;
  • System shutdown is impractical; and
  • Effective protective measures are in place.