OSHA Lockout/Tagout – The Control of Hazardous Energy Standard

Let’s take a deep dive into one of the most critical, complex and often mismanaged OSHA safety standards: The Control of Hazardous Energy standard, otherwise known as “Lockout/Tagout” or  “LOTO.”

The  Standard was developed to help protect workers from the accidental release of stored energy in equipment during maintenance or service operations.

A common misconception regarding LOTO is that it only applies to electrical energy.  Not true, it applies to any and all energy sources that feed into a piece of equipment including electrical, hydraulic, air, chemical, mechanical and even gravity.

Why is this safeguard so critical?  If equipment isn’t properly locked and tagged prior to commencement of service and maintenance activities, then stored energy could be released unexpectedly in the form of electricity, or movement of parts within the equipment.

This could result in serious or even fatal injuries such as electrocutions or amputations of fingers, or limbs.  LOTO provides a means of “locking out” and “tagging” these energy sources prior to start of maintenance and service activities in order to protect workers from these hazards

Unfortunately many serious injuries, and even fatalities, occur each year as a result of failing to properly lock and tag equipment prior to maintenance and service work.

Additionally, LOTO is one of the most commonly cited violation each year, and results in close to $2million in fines to US employers each year.

So, what do employers need to do in order to properly manage OSHA’s Lockout/Tagout Standard?  A lot!

Here are the basics:

  • Draft a written Lockout/Tagout “program” (policies and procedures) that meets all requirements of the LOTO standard and include in the company Health & Safety manual.
  • Identify and inventory each piece of applicable energized equipment in your facility.  These are equipment with multiple energy sources.   There are exceptions to this requirement of the LOTO standard and applies if a piece of equipment has only 1 electrical energy source, and it’s a plug.  There’s more to this exception, but this is the basic requirement.
  • Identify all energy sources feeding into each piece of equipment (ie: electrical, hydraulic, mechanical, etc…)
  • Draft “equipment specific Lockout/Tagout procedures” for each piece of equipment.  These procedures must include photos of each energy source, and detailed instructions for isolating and release stored energy for each.
  • Train all employees on their LOTO program:
    • “Authorized” training:  This training is intended for workers who are authorized to perform maintenance and service on equipment, but can also include operators in some instances.
    • “Affected” Training:  This training is for “every body else” who doesn’t actually perform maintenance or service, but need to understand LOTO’s purpose and how to identify a Lock or Tag so they don’t accidentally bypass them and injure another employee who’s working on a piece of equipment.
  • Provide appropriate locks and tags for use in LOTO.  If you use other locks and tags ensure they are visually different than the ones used in the LOTO program.
  • Conduct an annual “Audit” to ensure that all employees understand their training and how to follow LOTO procedures.

It’s a lot of work, but employers who fail to follow these requirements expose their employees to severe injuries, and even fatal events, not to mention huge fines and penalties from OSHA if they inspect your company.

Keep in mind that OSHA can issue violations for each aspect of the standard that a company fails to manage, which can quickly add up to $10s of thousands of dollars.