Lockout / Tagout
Lockout/tagout refers to the specific practices and procedures to safeguard employees from unexpected energization, startup or release of hazardous energy during service and maintenance of machinery and equipment.
Hazardous energy refers to the stored energy in a piece of machinery or equipment that has the potential to be released unexpectedly. Hazardous energy takes many forms including electrical, mechanical, hydraulic, pneumatic, chemical, and thermal. The unexpected release of stored energy is of great concern when maintenance and servicing of equipment must be performed. The Occupational Safety and Health Administration (OSHA) recognizes stored energy as a danger to employees and has developed specific standards to address the concern.
The OSHA standard for “The Control of Hazardous Energy (Lockout/Tagout),” 29 CFR 1910.147, addresses the practices and procedures necessary to disable machinery and equipment. These practices prevent the release of hazardous energy while employees perform service, repair and/or maintenance activities. Other requirements are set forth in 29 CFR 1910.269 and 29 CFR 1910.333 to protect employees working on electrical circuits and equipment. These provisions apply when employees are exposed to electrical hazards when working on, near or with conductors or systems that use electric energy.
OSHA (29 CFR 1910.147(b)) has defined servicing and maintenance as follows:
“Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubricating, cleaning or un-jamming machines or equipment and making adjustments or tool changes where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.”
The OSHA standard requires employers to establish an energy-control program, provide employee training and evaluate the program at least annually. It is important that safety officers have a thorough understanding of any activities employees undertake that may potentially include exposure to the release of hazardous energy. It is likewise crucial that the safety officer thoroughly understand the responsibility the employer has to protect its employees from these exposures.
Part of the duties of the safety officer may include the development of such an energy-control procedure. According to 29 CFR 1910.147(c)(4)(ii), the energy-control procedure must outline the scope, purpose, authorization, rules and techniques that employees will use to control hazardous energy sources, as well as a means to enforce compliance. The required procedure must contain the following:
- A statement on the intended use of the procedure;
- Specific procedural steps to shut down, isolate, block and secure machines or equipment;
- Specific steps designating the safe placement, removal and transfer of lockout/tagout devices and identifying who has responsibility for the devices;
- Specific requirements for testing machines or equipment to determine and verify the effectiveness of the devices.
Developing energy-control procedures can be time consuming and cumbersome. It is important not to fall into the trap of developing a generic procedure to be used with every machine or piece of equipment. OSHA has stated that the use of generic energy-control procedures alone are unacceptable, since generic procedures do not meet the provisions set forth in 29 CFR 1910.147(c)(4)(ii). In a letter of interpretation, OSHA states, “…a specific and documented procedure is necessary for most energy control situations because of the number of variables involved in controlling hazardous energy and the need for employees to carefully follow the sequential steps in the energy control procedure.”
Another responsibility assigned to safety officers is the development and implementation of training. According to 29 CFR 1910.147(c)(7), training must be conducted to ensure that employees understand the purpose, function and restrictions of the energy-control procedure(s). OSHA also defines the type of employees that need to be trained in the energy-control procedure.
The following are the categories of employees, “authorized,” “affected” and “other:”
“Authorized” employees are responsible for implementing the energy-control procedure and/or performing the maintenance and servicing of the machine or equipment. These employees will apply and remove the energy-isolating devices. It is extremely important that these individuals have the knowledge and skills necessary for safe application. Authorized employees need training in the following:
- Hazardous energy source recognition;
- The type and magnitude of the hazardous energy sources in the workplace; and
- The methods and means to isolate and control energy sources.
“Affected” employees are those employees who usually operate or use the equipment and machinery. They are required to be in the area when the equipment is being serviced but do not actually perform the servicing or maintenance. Affected employees need to be trained in the purpose and use of the energy-control procedure. These employees need to be able to:
- Recognize when the energy-control procedure is being used;
- Understand the purpose and procedure, and
- Understand the importance of not disturbing lockout/tagout devices or trying to start or use equipment that has been locked or tagged.
“Other” employees are those individuals whose work operations may be in the area where energy-control procedures are used. These employees must be trained on the energy-control procedure and understand not to remove lockout/tagout devices or try to restart, reenergize or operate machinery while the energy-control procedure is in place.
Training must be provided initially before starting service and maintenance activities. Certification of the training must be documented and should at a minimum include the employee’s name and date of training. Retraining is required for authorized and affected employees when there is a change in:
- Job assignment
- Machinery or process that creates a new hazard or
- Energy-control procedures.
Retraining is required when the employer has reason to believe that the employee’s knowledge or use of the energy-control procedure is inadequate. Additional training is required when an inspection reveals that corrective action and revision of the energy-control procedure is needed.
Under 29 CFR 1910.147(c)(6), OSHA requires that employers review their energy-control procedures at least once a year to ensure that the procedure is up-to-date and to identify any corrective action. This inspection evaluates the authorized employees’ knowledge of responsibilities and implementation of the energy-control procedure. An inspector, not involved in the energy-control procedure, must be able to determine the following:
- Employees are following the steps in the energy-control procedure;
- Employees involved know their responsibilities under the procedure; and
- The procedure is adequate to provide the necessary protection, and what changes, if any, are needed.
Each inspection should be documented and the certification should specify the following:
- Machine or equipment which was evaluated
- Date of the inspection
- Names of employees included in the inspection and
- Name of the person who performed the inspection.
The safety officer carries the responsibility to ensure that specific practices and procedures are in place to safeguard employees from the unexpected discharge of hazardous energy.
The following resources and technical links will assist in the development of an energy-control procedure(s) and a Lockout/Tagout Program.
Lockout-Tagout Interactive Training Program (http://www.osha.gov)
Control of Hazardous Energy (http://www.osha.gov/Publications/osha3120.pdf)
OSHA e-LOTO Software – Public Test Version (http://www.osha.gov)
OSHA Standard 29 1910.147CFR (http://www.osha.gov)
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