Complying with the Control of Hazardous Energy (lockout/tagout) standard can be a thorn in the side. Year after year, the standard is among the most frequent sources of OSHA citations. Why are there so many citations under lockout/tagout (LOTO)?
In many cases, it’s because employers overlook a crucial part of the standard. The standard says that you must have energy control procedures. You must also periodically inspect those procedures—and certify this to OSHA. One of the biggest reason employers get tripped up on LOTO is that they don’t follow—or at least can’t prove they follow–the inspection provisions. This story will show you two things:
There’s also a Model Form that you can adapt for your own facility and use to document inspections.
What the LOTO Standard Requires
The LOTO standard requires you to establish energy control procedures to ensure that dangerous equipment and machinery remains shut off and doesn’t unexpectedly energize, start up or release stored energy during servicing. To meet this requirement, you must set up a program and follow procedures to affix lockout devices such as combination locks and tagout devices such as warning tags, to prevent injuries to workers servicing the equipment and to others nearby.
The LOTO standard also requires employers to inspect their energy control procedures at least once a year to ensure that workers are following them. This follow-up effort is just as important as establishing the program in the first place.
How to Conduct the Inspection
To conduct an energy control procedures inspection you first need to designate an inspector. This should be somebody who services equipment at your facility. But there’s a restriction: The person who does the inspecting isn’t allowed to inspect energy control procedures that he or she actually uses. So inspectors shouldn’t inspect the equipment they service.
The inspector is supposed to review the energy control procedures to ensure they comply with OSHA standards and that all workers who are supposed to follow the procedures have copies of them. The inspector should also meet with the workers as part of the inspection.
The Lockout Inspection
If the inspection covers energy control procedures involving lockout, the inspector must meet with each worker who uses the procedure being inspected and ask them to explain their responsibilities under the procedures. If workers aren’t clear about certain aspects of the procedure, the inspector should explain the correct procedure and make a note letting management know that additional training may be needed.
The Tagout Inspection
While inspecting tagout procedures, the person conducting the inspection must do a review not just with each worker who uses the procedure but also with any workers who work in the immediate area or who use the particular equipment or machine. The inspector must meet with each worker and verify that the worker understands:
How to Document the Inspection
As far as liability is concerned, documenting the steps you take to comply with an OSHA standard is just as important as taking those steps in the first place. As lawyers like to say, if it isn’t documented, it never happened.
This principle is especially true in the realm of LOTO. Specifically, the LOTO standard requires you to set out procedures to control energy to shut down equipment and inspect those procedures at least once a year. The standard also requires you to certify that you’ve done an inspection and describe what the inspection covered. It’s often the documentation part that proves the trickiest. Lawyers warn that there have been many cases in which employers who did perform required inspections got cited because they couldn’t prove it.
How to Certify the Inspection
The Model Form is an example of how to properly certify an inspection. Although there’s no such thing as a one-size-fits-all form, there are standard kinds of information that all forms should include. Make sure that whatever certification you use lists the following items:
1. Inspection Date
The LOTO standard specifically requires listing the date the inspection was performed. One year from that date is your deadline for conducting your next inspection.
2. Location of Equipment
List the area or department of the facility in which the equipment or machinery covered by the inspected lockout/tagout procedures is located. Make sure you do a separate inspection and complete a separate certification form for each area of the workplace you inspect, even if the area contains the same machinery or equipment as an area you’ve already inspected. Keep in mind that the point of the inspection is to ensure that workers in each area understand the LOTO procedures.
3. Description of Equipment
Describe and provide specific identifying information of the equipment or machinery covered by the inspection, such as a model or serial number.
4. Description of Procedures
Use a check box to indicate what kind of procedures were inspected—lockout or tagout.
5. Workers Spoken To
List the name of each worker the inspector spoke to and the department in which they work. This is critical information to document because it enables you to show that you went over the procedures with all the workers the LOTO standard requires you to talk to.
6. Inspector’s Name
OSHA requires you to list the name of the inspector. It’s also a good idea to include the person’s extension and other contact information so you can easily follow-up with the inspector.
Just having energy control procedures isn’t enough. To avoid LOTO citations you must have a system of inspecting and certifying the effectiveness of your procedures. And you must be able to document your efforts because, as the lawyers like to say, if it isn’t documented, it didn’t happen.