What is lockout tagout?

Since the Occupational Safety and Health Administration (OSHA) introduced its lockout tagout standard in 1989, it has played a vital role in keeping employees safe on the job. This important safety practice involves de-energizing electrical circuits, closing valves, neutralizing extreme temperatures and securing moving parts so hazardous energy isn’t re-introduced while equipment is being serviced.

Lockout tagout programs do far more than keep workers safe, they:

• Saves lives by preventing an estimated 250,000 incidents, 50,000 injuries and 120 fatalities annually
• Cuts costs by significantly decreasing lost employee time and insurance costs
• Improves productivity by reducing equipment downtime

What are the U.S. regulatory requirements?

OSHA’s Control of Hazardous Energy regulation requires that energy sources must be contained during servicing and maintenance to ensure worker safety. Energy sources can include electrical, mechanical, hydraulic, pneumatic, chemical, thermal or other sources in machines and equipment.

• OSHA 29CFR 1910.147 — Control of Hazardous Energy
  General industry workers performing servicing and/or maintenance on machines or equipment and who are exposed to the unexpected energization, startup or release of hazardous energy.
• OSHA 29CFR 1910.333 — Electrical Safety
  Safety-related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized.
• ANSI Z244.1-2003 — Lockout Tagout and Alternative Methods
  A voluntary national consensus standard that represents several industry hazardous energy control best practices and also promotes greater flexibility through the use of alternative methods based on risk assessments and application of the hazard control hierarchy.

Program requirements

Q. What must be included in a lockout tagout program?

A. A typical lockout program can contain over 80 separate elements. To be compliant, a lockout tagout program must include creating, maintaining and updating equipment lists and hierarchies, task-specific procedures and workplace regulations (such as confined space entry requirements.

Q. What are some lockout tagout requirements, versus best practices?

A. An annual review of lockout procedures is recommended, while some best practices include program standardization, lockout tagout software, annual authorized/affected training (authorized will be more frequent), updating isolation points, management of change, contractor training and device inventory.

Q. What is the responsibility of the host employer with regard to on-site contractors and lockout program implementation?

A. The host employer often will have greater familiarity with the energy control procedures used at the host facility. However, at 29 CFR §1910.147(f)(2)(i), the standard requires the host and contract employers to inform each other about their respective energy control procedures. Such coordination is necessary to ensure that both sets of employees will be protected from the hazardous energy.

The contractor must take reasonable steps, consistent with its authority, to protect its employees if the contractor knows, or has reason to know, that the host’s energy control procedures are deficient or otherwise insufficient to provide the requisite protection to its employees.

Q. If you are only operating powerlifting equipment and docks is a lockout program required?

A. Yes, in the standard shipping and receiving areas or docks you will need machine specific written procedures for dock levelers and locks, battery chargers, palletizers, cranes, hoists, and anything hard-wired to an electrical panel will need written lockout tagout procedures.

Q. OSHA 1910.147 does not cover construction and agriculture employment. Where can I find information for these industries?

A. Construction has its own code of regulations so it is not covered in general industry. Agriculture CFR 1928 doesn’t have any mention of lockout tagout, but the NIOSH backed National Ag Safety Database has lockout program recommendations. All the steps follow OSHA 1910.147.

For implementing a program for agriculture, look at all the equipment in the facility and identify isolation points for each piece of equipment. Procedures should be created and devices, locks and tags should be bought to isolate the equipment during servicing. Train your authorized employees on when, how and why they need to lockout while servicing equipment.

Q. Can you provide additional information on the minor tool adjustment clause?

A. OSHA has a few letters of interpretations that cover the minor servicing clause. Consider the lockout procedure as the first procedure created for your equipment to know how to completely remove all hazards. Minor tool adjustment should be used for routine tasks done by operators. Standard operating procedures should be created for any minor serving to ensure the operator is not exposed to any hazards during minor servicing.

Q. Do you have a lockout tagout offering specifically for the food processing industry?

A. Brady offers lockout procedures and tags that are wash-down resistant and metal detectable. We can also assist in developing standard operating procedures for equipment during washdown operations.

Q. What are the paperwork requirements for group, complex or simultaneous operations?

A. Lockout tagout paperwork requirements vary by company. Best practices are to have a log of all servicing that requires lockout with sign-out sheets of all isolation devices. Any permits needed to complete the service (hot work, confined space or working at heights) should be copied and kept with the service log.

Procedures

Q. With thousands of machines and procedures, can I group machines that are similar to make the periodic inspection easier?

A. Yes, OSHA allows the grouping of same or similar equipment and procedures to ease the burden of periodic inspections.

A best practice is to have a specific procedure for each individual machine, posted on or near the machine. Even if you have two identical machines, it's still preferred to have a procedure for both. This helps prevent confusion and demonstrates your thoroughness to inspectors.

OSHA specifically outlines in their “Compliance Directive” that this level of detail is optimum and therefore allows the grouping of same/similar procedures and machines to encourage and maintain this high level of safety. The grouped machines must have the same or similar control measures.

Q. Do you have any recommendations for successful and appropriate grouping?

A. Some companies develop generic energy control procedures and supplement them with checklists or appendices to address various, distinct equipment. This type of procedure may be considered a single energy control procedure (instead of multiple procedures) for inspection purposes if all of the criteria for grouping same or similar equipment are met. However, if checklists or appendices address equipment that does not all use the same or similar types of control measures, the employer is required to divide machinery and equipment into groups based on the same or similar types of control measures.

Once this is accomplished, an employer may inspect and review the generic energy control procedure in conjunction with each distinct group of equipment referenced in the relevant checklists or appendices.

Q. Are you required to have machine-specific procedures if all maintenance is done by contracted work only?

A. Yes, you need machine-specific procedures for all equipment at your facility, even if contractors are the only people authorized to work on the equipment. Even if there are no authorized employees, training is required for all employees and an annual procedure review needs to be complete, with any changes communicated to the contractors before servicing.

Q. Could you provide a sample lockout procedure?

A. Download a sample procedure here.

Q. What are the exceptions for equipment that does not require a procedure?

A. To be exempt, equipment must meet all eight criteria from 1910.147 (c)(4)(i):

1. No stored or residual energy
2. Single source readily identified and isolated
3. Single isolation point must de-energize to zero energy state
4. Lockout is performed for that point
5. Single lockout device
6. Exclusive control of authorized employee
7. No hazards to affected employees
8. No accidents involving the equipment

Q. In what case does a single energy source NOT require a procedure?

A. This is typically all plug and play equipment, such as laptops, office equipment, fans, power tools, portable equipment, and anything that is hardwired and easily isolated with a single power cord or isolation point. Lockout tagout must still be followed, but you do not need a written procedure.

Q. What software can be used to create procedures?

A. Brady offers LINK®360 procedures software to create, manage and audit visual lockout procedures.

Q. If contractors are deemed as authorized, can they write procedures on behalf of the company they are working for?

A. Yes, although these procedures are best developed by employees familiar with the facility to ensure the correct disconnect is being used. Outside contractors unfamiliar with the equipment may miss an energy source if the authorized employees are not involved in verifying the procedures achieve a zero energy state.

Applications

Q. How do you manage "exceptions" where a zero energy state cannot be used due to the task at hand?

A. This is covered under the OSHA 1910.147(f)(1). When lockout or tagout devices must be temporarily removed from the energy isolating device and the equipment energized to test or position the equipment, the following sequence of actions shall be followed:

• Clear the machine or equipment of tools and materials in accordance with paragraph (e)(1) of this section
• Remove employees from the machine or equipment area in accordance with paragraph (e)(2) of this section
• Remove the lockout or tagout devices as specified in paragraph (e)(3) of this section
• Energize and proceed with testing or positioning
• De-energize all systems and reapply energy control measures in accordance with paragraph (d) of this section to continue the servicing and/or maintenance

Q. What are OSHA standards for lockout transition to other shifts and personnel?

A. Generally, the transfer of responsibility can be accomplished by the oncoming shift accepting control of the system involved prior to the release of control over the system by the off-going employees. The orderly transfer of personal lockout tagout devices between off-going and on-coming employees must ensure there is no gap in coverage between the off-going employee's removal of their lockout device and the on-coming employee's attachment of their device.

Q. Can another worker be used as an active lockout?

A. No. The OSHA standard specifies mechanical devices and tags must be used. One of the OSHA cases or interpretations involves an authorized employee watching a switch while another authorized worker performs equipment maintenance. While convenient, OSHA specifically indicated that this method is not as reliable as a mechanical device.

Q. In a heavily automated industry, do you have advice for how to verify isolation?

A. Testing the electrical parts with a meter is recommended to verify isolation when testing at the control panel is not possible. The electrical disconnect that is wrongly isolated should be labeled and the procedure updated with the correct disconnect.

Q. What are some recognized verification methods for ensuring air is bled out of a system besides gauges?

A. There are a few ways to verify pressure has been bled off. Noise is a common practice for compressed air lines since dump valves make a loud noise when releasing pressure. Depending on the location of the isolation point, connecting air tools to the line to bleed off the line is another way to verify.

Q. Doesn't OSHA require machines installed since 1990 to use lockout instead of tagout only?

A. Yes, tagout is very rarely used. Most isolation points have been replaced to allow for a lock to be placed or new devices have been developed to isolate those energy sources.

Devices

Q. What is a good estimate for the total number of lockout devices needed for your lockout program?

A. The total number of lockout devices can vary by organization. The best way to determine to good estimate for your organization is by taking the following steps. 

1. Decide how many stations or departments need a lockout device cabinet or board.
2. Discuss with authorized employees where the cabinet or board should be located based on the location of equipment, with high equipment areas being the key factor for Lockout tagout station placement.
3. Look at the high hazard equipment areas (boiler, chiller, generators, and facilities equipment rooms) and production departments. Count up the total number of devices required for all the written machine-specific procedures in the desired area and order 10% of the total number of devices. If the boiler room has 50 pieces of equipment and 100 ball valve devices, the boiler lockout station should have 10 ball valve devices. The need to lockout all equipment at your facility will never happen, but using 10% as a starting point for the initial order will be a good starting point.
4. Monitor the lockout stations’ devices with an inventory list to see if more devices need to be ordered after the initial order.

Q. Do you have a collection of the various recommended lockout devices?

A. You can browse the lockout tagout section of our website or by downloading our digital catalog.

Training requirements

Q. How can I get a formal training class for my employees?

A. Brady offers a Lockout Train the Trainer Course, as well as additional lockout tagout training opportunities.

Q. What is sufficient hands-on training documentation?

A. You need the authorized employee to sign off that the trainee fully understands the equipment and the lockout tagout program.

Q. How often is lockout tagout training required?

A. Employees must be trained when they are hired, and then they must be retrained if there is a gap in behavior, knowledge or changes to procedures. While lockout tagout training is not required annually, it is a best practice to provide annual training that is completed during the annual review of equipment.

Q. Is it a requirement to train contractors on our company's lockout program if they have their own program that they are trained on?

A. Yes, any contractor authorized to service equipment must meet your lockout programs requirements and be trained on the written program's procedures. Depending on your written program, contractors may need to group lockout with an authorized employee.

Q. Who is responsible if outside contractors work on my equipment?

A. The responsibility is shared. The host employer often has greater familiarity with the energy control procedures used at the host facility; however, the standard requires the host and contract employers to inform each other about their respective energy control procedures. This coordination is necessary to ensure both sets of employees are protected from the hazardous energy.

Annual audit requirements

Q. What is required in an annual audit?

A. The annual periodic inspections must be conducted by an "authorized employee" and contain at least two components:

1. An inspection of each energy control procedure
2. A review of each employee’s responsibilities under the energy control procedure being inspected

Q. What annual audit documentation is required?

A. Employers must certify, in accordance with §1910.147(c)(6)(ii), that the prescribed periodic inspections have been performed. The certification must specify:

1. The machine or equipment on which the energy control procedure was used
2. The date of the inspection
3. The names of the employee(s) included in the inspection
4. The name(s) of the person(s) who performed the inspection

Q. What is the difference between a review and an audit?

A. Annual review, audit and inspections all refer to the same requirement.

Q. Is a second-person verifying equipment lockout considered an annual review of the procedure?

A. The second person who verifies equipment must be authorized and must ensure all employees who maintain that equipment are knowledgeable about the procedure and responsibilities, as well as document that inspection.

Q. Does the annual inspection need to be performed at a set time, or can it be done throughout the year?

A. It doesn't have to be completed all at once during the same time each year, which means it can occur throughout the year.

Q. Do I need to do an annual inspection for each machine on the plant floor?

A. Generally, yes. However, OSHA does allow an employer to group separate, machine-specific lockout tagout procedures into one procedure for purposes of complying with the lockout tagout standard, as long as the machines or equipment in the group have the same/similar types of control measures. Energy control procedures used less than once a year need be inspected only when used.

Q. Do all authorized employees need to participate in the annual review of each procedure?

A. The lockout tagout standard does require that the procedure being inspected to be reviewed with all authorized employees as part of the periodic inspection (reference 1910.147(c)(6)(i)(C)).

Q. How formal or comprehensive is the annual audit?

A. In order to meet the review requirement, the auditor does not have to observe every authorized employee implementing the energy control procedure on the equipment on which they perform servicing/maintenance. Rather, the auditor performing the inspection may observe and talk with a representative number employees implementing the procedure in order to obtain a reasonable reflection of the servicing/maintenance practices being evaluated.

To supplement this representative inspection sampling approach, additional supplemental reviews must still be performed with all authorized employees who are reasonably expected to implement the procedure during the year. Group meetings may be the most effective way to meet the review requirements and to re-establish employee procedure responsibilities and proficiency.