How to Provide Compliant LOTO Training

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

 

Section 1910.147(c)(7) of the LOTO standard requires employers to train employees about the energy control program’s purpose and ensure that employees have the necessary knowledge and skills to safely apply, use and remove energy controls. Here’s what you need to do to comply.

What LOTO Training Must Include

Training requirements vary depending on what kind of employee the person is. There are 3 possibilities:

1. Authorized Employees

 

An authorized employee is a person who locks out or tags out machines or equipment to perform servicing or maintenance on it. An affected employee becomes an authorized employee when that employee’s duties include performing servicing or maintenance covered under the LOTO standard.

Training required: Authorized employees must be trained to recognize hazardous energy sources, the type and magnitude of energy available in the workplace and the necessary methods of energy isolation and control.

2. Affected Employees

 

An affected employee is an employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed.

Training required: Affected employees must be instructed in the purpose and use of the energy control procedure.

 

3. Other Employees

 

Other employees are those whose work operations are or may be in an area where energy control procedures may be used but aren’t authorized or affected employees.

Training required: Other employees must be instructed about the procedure and about the fact that restarting or reenergizing locked out or tagged out machines or equipment is prohibited.

Additional Training Requirements When Tagout Is Used

 

When tagout systems are used, employees must also be trained in the limitations of tags as a protective device, including the fact that tags are only a warning device without the physical restraint provided by a lock and that because they don’t stop energy flow, tags can but must not be allowed to evoke a false sense of security. Tagout training must also explain:

  • The purpose served by tags;
  • That tags attached to an energy isolating means must not be removed without approval of the authorized person responsible for removal;
  • That tags must never be bypassed or ignored;
  • That for tags to be effective, they must be legible and understandable by all authorized and affected employees and employees whose work operations are or may be in the area;
  • That tags and their means of attachment must be made of materials able to withstand the conditions in the workplace environment that can cause them to deteriorate; and
  • That tags must be securely attached to the energy isolating device(s) so they can’t be accidentally or inadvertently removed.

Retraining Requirements

 

Authorized and affected employees must also receive retraining whenever:

  • Their job assignments change;
  • There are changes in machines, equipment or processes that pose a new hazard; and/or
  • The energy control procedure changes.

Additional retraining must be provided whenever a periodic inspection reveals or the employer otherwise has “reason to believe” that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.

Retraining must reestablish the employee’s “proficiency in” and, if necessary, introduce him/her to any new or revised energy control methods and procedures.

Documentation of Training

 

The employer must certify that employee training has been accomplished and is being kept up to date. Certification must list each employee’s name, and the dates of training.