Lockout / Tagout (LOTO) Program

The numbers are staggering: Lockout/Tagout (LO/TO) violations are consistently among OSHA’s 10 most common violations every year. Without proper LO/TO procedures, approximately three million workers are at risk every day, and compliance with OSHA’s LO/TO standard can prevent an estimated 120 fatalities and 50,000 injuries each year.

Fortunately, regulations and accepted best practices make it easy to establish an effective LO/TO program that will save lives and create a culture of safety in facilities large and small.

This article will provide an overview on what’s required of a LO/TO program, when LO/TO must be used, and what work must be done to ensure a safe working environment.

OSHA LO/TO Program Requirements

The OSHA LO/TO standard for general industry (29 CFR §1910.147) requires that employers establish a lockout/tagout program whenever workers are involved in servicing or maintaining machines that would expose them to hazardous energy in the event of unexpected energization or the release of stored energy. Each facility’s LO/TO program must protect employees from all sources of hazardous energy, ranging from electrical energy to hydraulic pressure, and even including gravity and heat.

The OSHA LO/TO standard sets the minimum requirements that must be included in a facility’s LO/TO program. These requirements state that employers must:

• Establish written energy-control procedures for:
  • disconnecting the source of energy supply from machines
  • using lockout or tagout devices on the energy-isolating devices to prevent re-energization
  • protecting workers from stored or potentially re-accumulated energy
• Train employees on the energy-control program, including the safe application, use, and removal of energy control devices
• Evaluate the LO/TO program on at least an annual basis to ensure procedures are being followed and that they are still effective in preventing employees from being exposed to hazardous energy

OSHA requires the written procedures to include at least the following information:

• A description of how to use the procedures
• Specific procedural steps to shut down, isolate, block, and secure each type of machine or system
• Specific steps designating the safe placement, removal, and transfer of lockout/tagout devices, and identifying the person (or people) responsible for the lockout/tagout devices
• Requirements for testing machines and systems to verify the effectiveness of the lockout devices, tagout devices, and other energy-control measures

Within the boundaries established by the OSHA standard, employers have the flexibility to develop custom procedures suitable for their situation and the types of machines they work with.

Building an Effective LO/TO Procedure

OSHA requires employers to develop and use written procedures describing what will be done to control hazardous energy. An employer’s LO/TO program should cover the following:

• Necessary LO/TO training should be provided
• All energy sources must be de-energized, disconnected from the machine, and locked out before work begins to prevent inadvertent machine energization
• Workers must verify that the energy source has been isolated
• A machine’s stored energy should be dissipated, whenever possible
• Employees must verify that hazardous energy cannot re-accumulate
• The employer must ensure workers have taken all necessary steps to prevent injury from the release of the stored energy

Broadly, the written LO/TO program must answer the following questions:

• What must employees know and do to control hazardous energy?
• What are the circumstances when LO/TO procedures apply?
• What is the scope, purpose, authorization, rules, and techniques that will be used to control hazardous energy?
• How will compliance with the LO/TO Program procedures be enforced?

What Does "Lock Out" Mean?

Most de-energization procedures involve shutting down and “locking out” a machine to keep workers safe. This is done with a “lockout device,” which physically holds an energy-isolation device in a safe or “off” position. The device physically locks into place such that no one can remove the device except the person who applied the device.

One example of a lockout device involves working on an electrically-powered machine. The source of energy is removed by opening a breaker, and the breaker is then locked into the “off” position using physical locks. Each person working on the machine places their lock on the breaker, and each person has the only key that will open their lock. This ensures that one person cannot remove all the locks while another person is still working on the machine.

Other types of locking devices may be applied to valves, steering wheels, switches, lock boxes, and pull-chains. Graphic Products carries padlocks and accessories, lockout kits and stations, and lockout devices to help keep employees safe in lockout situations.

What Does "Tag Out" Mean?

It may not always be physically possible to lock out an energy source. In these instances, a company’s LO/TO program will specify a tagout procedure, which uses visual communication (in lieu of a physical lock) to warn other employees against re-energizing a machine until it is safe to do so. In such situations, tags—featuring a prominent warning—are fastened to the energy-isolating device to warn about the dangers of re-energizing the machine while it is being serviced. Graphic Products carries a variety of safety tags suitable for tagout situations.

Given that a tag is easier to defeat than a lock, it provides less protection. For instance, a tag may be accidentally removed, or an employee may remove a tag due to miscommunication. If tagout is used on a machine that can be locked out, the employer must ensure additional measures are in place to give workers the same level of protection that using a lockout device would have provided.

What Must Be Done Before Work Starts

Before working on a machine, the following steps must be completed in sequence and according to the specific energy-control procedures established in the LO/TO program:

1. Prepare for shutdown
2. Shut down the machine or system
3. Disconnect and isolate the machine or system from all energy sources
4. Apply the lockout or tagout device(s) to the energy-isolating device(s)
5. Release, restrain, or otherwise render safe all stored or residual energy
6. If appropriate, install isolating devices such as pipe blocks
7. If re-accumulation of hazardous energy is possible, regularly verify that energy has not re-accumulated to hazardous levels
8. Verify the isolation and de-energization of the machine

Removing Lockout or Tagout Devices and Re-energizing

If someone removes a lock or tag and re-energizes a machine while people are still working, someone may be seriously injured or killed. It is extremely important that only the person who applied a lock or tag remove that lock or tag.

The specific actions required to accomplish these steps should be in the LO/TO program procedures for the machine or system. Generally, an employee should:

• Inspect the machine or system and its components to ensure it is operationally intact and that nonessential items are removed from the area
• Check to assure that everyone is positioned in a safe location

After all workers have removed their lockout or tagout devices, but before re-energizing the machine, everyone who works with the machine, as well as those in the area where the work on the machine was performed, must be informed that the LO/TO devices have been removed and the machine is capable of being re-energized.

Periodic LO/TO Program Review

Employers should conduct periodic reviews of their LO/TO program—at least once per year, per OSHA standards—to ensure employees are familiar with their responsibilities and that the specified energy-control procedures are being followed. The person doing the review must be an authorized person who is not involved with the LO/TO procedure being reviewed. The review should determine the following:

• Are employees following the energy-control procedures?
• Do employees know their responsibilities as defined by the procedures?
• Does the procedure provide the necessary protection? If not, what changes are needed?

For a lockout procedure, the periodic inspection must include a review of each authorized employee's responsibilities under the energy-control procedure being inspected.

For a tagout procedure, the review must also include all affected employees. Affected employees are those who are not involved in the maintenance or serving work, but who use or work with the machine, system or component being tagged out. Affected employees must be able to recognize tags and their meaning, know about tagout procedures, and understand that tagged out devices must not be activated.

In addition, the employer is required to certify that the designated inspectors performed the required inspections. This certification must specify the following:

• Identification of the machine for which the energy-control procedure was used
• Date of the inspection
• Names of the employees included in the inspection
•  The name of the person who performed the inspection

How Can Graphic Products Help You Establish a LO/TO Program?

Graphic Products carries training materials in a variety of media—including DVDs, booklets, posters, and CD-ROMs—to educate employees on proper lockout/tagout procedures.

Labeling and signage can alert employees to electrical hazards and provide the necessary information in lockout/tagout situations. DuraLabel industrial label and sign printers by Graphic Products can assist in developing custom visual communication. With several, tough-tested printers and more than 50 specialty label supplies, you’ll find the right tools to help your employees remain safe.

If you’re looking for an outside perspective, our Compliance Assessment Services provide on-site services that include a safety compliance analysis, arc flash study, and electrical safety training.