On April 4, 1991, GM millwright Daniel Smith was killed when the conveyor he was repairing unexpectedly started up. Sadly, many workers continue to lose lives and limbs in machine accidents like this. That’s why the OSHA Lockout/Tagout (LOTO) standard (Sec. 1910.147) requires employers to ensure machinery and equipment is shut down and doesn’t energize, or start up, during servicing, repair or maintenance operations. But while they serve an important purpose, the OSHA rules are technical and hard to apply to practical operations. So it’s not surprising that LOTO remains a leading source of OSHA citations.
The key to avoiding Daniel Smith-type injuries—and OSHA LOTO citations—is to implement an Energy Control Plan (ECP, which we’ll refer to by its common name “LOTO program”) for safe repair and maintenance of machinery and equipment that’s subject to unexpected energization. Here are the 13 things you have to do to comply with LOTO program requirements.
The first thing you need to do is figure out which, if any, of your operations require a LOTO program. Rule of thumb: LOTO requirements apply to any operations for controlling energy during the servicing or maintenance of machines and equipment where unexpected energization, start up or release of stored energy could harm workers. But there are some key exceptions:
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 equipmentEquipment 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:
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Your LOTO program must indicate the method you use to control the release of hazardous energy. The options:
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The LOTO standard says you must set out a “clear and specific” lockout (or tagout) procedure for controlling hazardous energy. The words “clear and specific” aren’t window dressing. Many an employer has been cited because it procedure wasn’t clear and specific enough. To avoid citations, the procedure must list—at a minimum:
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The individual who performs the actual energy control procedure must be what’s called an “authorized employee,” i.e., a person who locks out or tags out machines or equipment to perform servicing or maintenance on that machine or equipment, as opposed to what’s called an “affected employee,” i.e., one whose job requires him to operate or use the machinery or equipment being serviced or maintained or whose job requires him to work in the area where the servicing or maintenance is performed.
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Your energy control procedure must provide that service/maintenance on machinery/equipment can begin only after all of the following steps are taken in this ordere:
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There also needs to be a procedure to ensure that the lockout/tagout device isnt removed and power to the machine/equipment isn’t restored, unless and until the authorized employee checks the work area to verify that nonessential items have been removed,
machine or equipment components are operationally intact and all employees have been safely positioned or removed.
The energy isolating device(s) must be removed by the authorized employee who attached it. Exception: If the authorized employee isn’t available, it may be removed by somebody else, as long as the Energy Control Procedure includes specific steps and training requirements for removal by another person and the alternative removal procedure is just as safe as removal by the authorized employee and steps are taken to verify that the authorized person isn’t at the facility, reasonable efforts and were taken to find to let him know the device has been removed before he resumes work at the facility.
The authorized employee must ensure that all affected employees are notified after the lockout or tagout device(s) has been removed. The machine/equipment can’t be restored to service until after all affected employees receive notification.
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The energy control procedure should provide that if the lockout/tagout device is temporarily removed from the energy isolating device so the machine/equipment can be tested or positioned, the following steps must be taken in this order:
There must also be specific procedures to ensure the continuity of lockout or tagout protection through changes in shifts or personnel, including procedures for the orderly transfer of lockout or tagout device protection between the off-going and oncoming employees.
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Like some employers, you might rely on an outside contractor or subcontractor to carry out your energy control procedure. In this case, make sure you and the contractor notify each other of your respective lockout/tagout procedures and decide which procedures to use. If you use your own procedure, make sure the contractor’s employee’s understand and comply with it; if you use the contractors procedure, make sure your own employees understand and comply with it.
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You must provide locks, chains, wedges, key blocks, adapter pins, self-locking fasteners or other hardware for isolating, securing or blocking machines or equipment from energy sources. The actual lockout devices and tags you use must also meet specific OSHA requirements.
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You must inspect your energy control procedure at least once a year to verify that the procedure and LOTO requirements are being followed. Inspection must be carried out by an authorized employee who is not utilizing the energy control procedure being inspected and include reviews with authorized employees who are using it (and affected employees affected by it). Make sure you document each inspection by creating a written certification that lists the:
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You must train and instruct your workers about the purpose of your energy control program and ensure they have the necessary knowledge and skills to play their role under it. The substance and objectives of training vary depending on who’s being trained:
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You must ensure authorized and affected employees receive retraining whenever:
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Finally, you must document that LOTO training has been accomplished and is kept up to date by creating a written certification that lists each trainee’s name and the date(s) training was provided.
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MODEL LOCKOUT/TAGOUT PROCEDURES & PROGRAMS