Why Manufacturers Need an OSHA-Compliant Lockout/Tagout Program

Have you ever had an employee injury or death because of a machine that wasn’t completely turned off?

Even if you’re among the lucky few who haven’t experienced this type of incident, nationwide lockout/tagout violations are on the rise. With an increase of 279 violations between 2021 and 2022, OSHA inspectors are cracking down on one of the highest-risk situations on the floor.

2023’s numbers are already climbing, and you can’t afford to get flagged for non-compliance—or worse, risk the safety of your employees. There’s never been a more crucial time for a full-scale, OSHA-compliant lockout/tagout program for your business. But why is it so urgent for manufacturing leadership to establish these protocols—and what are the consequences if you delay?

What is a lockout/tagout program?

A lockout/tagout program (LOTO) provides your employees with a series of protocols and procedures for controlling hazardous energy when shutting down equipment for maintenance, repair, or servicing. Shutting down a machine before touching it might sound like common sense, but OSHA consistently finds that lack of LOTO compliance results in about 120 unnecessary deaths and 50,000 avoidable injuries every year.

In fact, failure to properly follow lockout/tagout regulations consistently ranks in the top 10 most frequent OSHA citations.

Luckily, following LOTO protocols isn’t a headache when you have a solid OSHA compliance program—and compliance isn’t as unaffordable as you may think.

Still on the fence about investing in your LOTO program? Here are four key reasons you need an OSHA-compliant lockout/tagout program in 2023.

Lockout/Tagout Programs Protect your Workers

If you have unchecked hazardous energy running around your floor, it’s not a matter of if someone gets hurt, it’s a matter of when.

Manufacturing dangers aren’t always the obvious trip hazards or loose wires. If you don’t follow LOTO procedures, you’re putting your employees at serious risk for:

Cuts and amputations
Severe electrical shock
Blindness
Multiple-degree burns (flame and chemical)
Toxic inhalation
Fatalities

Even in the best-case scenario, minor injuries will hurt worker morale, slow productivity, and increase your labor and insurance expenses. In the worst-case scenario, you could be looking at worker fatalities—and there’s no faster way to lose the trust of your people.

Bottom line: without a comprehensive, repeatable compliance program, you’re putting your employees at risk.

Lockout/Tagout Programs Avoid Common Willful Violations, Fines, and Reputational Damage

Not all OSHA violations are created equal. “Other-Than-Serious” violations which don’t threaten the health and safety of workers may not even carry any monetary fines—just a slap on the wrist.

OSHA’s LOTO standard (29 CFR 1910.147) does not fall under this “harmless” category. It mandates that employers must have a written energy control program that outlines procedures for controlling hazardous energy. Failure to comply with these regulations can result in citations, fines, and penalties. And violating this standard is typically regarded as a willful violation—something you’ve done to deliberately ignore OSHA standards.

At the end of the day, OSHA doesn’t care whether or not your lack of a LOTO program was intended to break the rules. Intent simply doesn’t matter when the consequences can be devastating. So if one of your employees gets killed due to a willful violation, that’s not just a small fine for your company—it’s up to a whopping $250,000 and criminal charges.

For many small manufacturers, $250,000 could spell disaster and bankruptcy if the reputational damage drives customers away. LOTO compliance programs prevent these expensive fines and maintain your reputation and customer relationships.

Lockout/Tagout Programs Keep your Floor Running Smoothly

What issues cause the biggest disruptions on your floor? Machine malfunctions? Employee accidents? Maintenance shutdowns? Whatever your answer might be, we’re confident you didn’t say “safety protocols.”

Why? Because even though enforcing (and reinforcing) safety procedures might take a few hours off your clock, worker injuries take around 70 million days away from manufacturers around the country every year. That’s not surprising given that the average worker needs around 24 days for a full recovery. That’s 24 days of lost labor, slower productivity, workers comp pay, and OSHA investigations.

And that’s not including the time needed to fix any damages and/or install safety mechanisms.

Following a clear LOTO program doesn’t just protect your workers and your wallet: it also keeps your productivity on track and your profits rolling in.

Lockout/Tagout Programs Prepare your Business for the Future

OSHA laws can update every single year—and staying current is a difficult and confusing lift for manufacturers of all sizes. That’s why it’s so critical to set yourself up for success when they shift.

For instance, OSHA laws regarding LOTO haven’t been updated since 1989. However, in 2019, OSHA started looking into how technological advances might require changes to the regulations. This means it’s very possible we might see significant changes to the law and more aggressive enforcement in the near future.

The best way to combat OSHA changes is by designing a reliable program that simply needs a few updates and regular employee training sessions and better yet, for your safety committee to stay on top of it and compliant. However, you can’t update a program that doesn’t exist—and you certainly can’t train your staff on it.

Having an up-to-date, repeatable LOTO compliance program means you’re in a position to grow with regulations rather than fight against them. When you have clear protocols, you can train your staff and introduce new procedures without starting from square one. Plus, you have a written index of those procedures for anyone who needs a refresher. When you have a base line, you can reevaluate, improve, and grow stronger over time until you build a lasting safety culture.

Most OSHA violations aren’t intentional. They don’t happen because you want to hurt your employees or your business. They happen because you don’t have the tools to successfully enforce safety regulations.

At Berg Compliance, we understand that frustration. That’s why we offer affordable and customizable compliance programs for manufacturers of all sizes.

You don’t need to wait to get LOTO compliant. Call 512-457-0374 or click here to schedule your free consultation today.

By Russell Carr|2023-08-21T10:44:57-05:00August 21st, 2023|OSHA Health & Safety, OSHA Texas Laws & Regulations, Safety Training, Texas OSHA Compliance|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

Why Manufacturers Need an OSHA-Compliant Lockout/Tagout Program