A Guide to LOTO's Eight Critical Elements

While performing lockout audits for clients, I commonly observe the misuse of lockout locks and tags.

THE lockout/tagout standard--29 CFR 1910.147--is arguably the best OSHA standard ever written. For the price of a lock and tag, employees can be confident they are protected from the sudden release of hazardous energy while performing maintenance, cleaning, or servicing activities on equipment. When performed correctly, lockout/tagout is extremely beneficial; however, when performed incorrectly, serious injuries and fatalities may occur.

During the past 18 years, I've had the opportunity to review lockout/tagout programs for a broad range of industries, such as the chemical, nuclear, pharmaceutical, steel, food, furniture, paper, semiconductor, and textile industries. Listed below are critical elements necessary to ensure an effective lockout/tagout program.

1. Servicing and Maintenance activities versus lockout/tagout
I recently observed a machinist reprogramming a CNC machine with his arms entirely inside the machine. When questioned about lockout, the machinist stated: "This is a normal production operation--lockout is not required." This is a very unsafe practice; a multiple amputation could occur if the machine were to suddenly become energized.

Do your employees follow lockout/tagout when changing the grinding wheel on an abrasive grinder, adjusting the belt speed on a drill press, or changing a light ballast on a fluorescent light? Lockout procedures must clearly define what constitutes normal production operations versus when equipment must be locked out.

2. Identifying all energy sources: equipment-specific procedures
To ensure employee safety, it is imperative that all potential energy sources are identified. Employees typically apply locks and tags on the main electrical disconnect; however, additional energy sources may exist, such as thermal, hydraulic, pneumatic, radioactive, gravity, or chemical energy. OSHA requires equipment-specific lockout procedures for equipment containing two or more energy sources. (See 29 CFR 1910.147(c)(4).)

3. Correct identification of energy-isolating devices
When isolating energy sources, employees frequently lock out control circuit-type devices, such as on/off switches, emergency stops, interlocks, and three-way selector switches. This is a very unsafe practice; control circuits do not isolate the flow of electrical energy to a piece of equipment.

To achieve proper equipment isolation, an energy isolating device, such as an electrical circuit breaker or main electrical disconnect, must be locked out. For OSHA's explanation of an energy isolating device, refer to 29 CFR 1910.147(b).

4. Protection of all employees
Lockout/tagout ensures employee protection while performing servicing, maintenance, and other activities on equipment. However, lockout/tagout is seriously compromised when more than one employee is working under the same lockout/tagout device. An employee could inadvertently remove his/her locks and tags, seriously exposing unprotected employees. The best practice is for each employee to apply his personal lockout/tagout devices to each energy-isolating device. For complex jobs involving several employees and multiple energy sources, group lockout may be utilized.

5. Correct selection and use of locks
While performing lockout audits for clients, I commonly observe the misuse of lockout locks and tags. For instance, I once observed 300 employees using identically keyed locks--employees could remove others' locks. In another case, a supervisor had the duplicate keys for all of her employees' locks. Another problem is securing tool cribs and personal lockers with lockout locks.

The best practice is to use uniquely keyed locks that come with only one key. Also, lockout and tagout devices must be standardized--see 29 CFR 1910.147(c)(5)(ii)--and must not be used for any other purpose.

6. Verification of isolation: 'Lock-Tag-Try'
Verification of isolation must be performed prior to commencing servicing and maintenance activities. Many companies refer to their lockout program as "Lock-Tag-Try." In most cases, isolation may be verified by attempting to operate the machine. However, electrical repairs require verification with electrical test equipment to verify a deenergized condition. (See 29 CFR 1910.147 (d)(6) and 29 CFR 1910.333 (b)(2)(iv).)

7. Training of all employees
Most companies train employees who apply locks and tags to equipment (authorized employees). However, equipment operators as well as employees who may be in close proximity to equipment that is locked out (affected employees) also must be trained. In addition, all other employees, such as management employees, need to receive awareness training on lockout/tagout and the prohibition against removing lockout locks and tags from energy-isolating devices or attempting to operate locked out equipment. (See 29 CFR 1910.147 (c)(7)(i).)

8. Periodic (annual) inspection of lockout program
29 CFR 1910.147 (c)(6)(i) requires employers to conduct an annual review of their lockout/tagout program to verify program effectiveness. Each equipment-specific lockout procedure should be field-reviewed to ensure lockout/tagout is being performed correctly. Deficiencies must be corrected through revised procedures, training, or both.

This article appeared in the March 2006 issue of Occupational Health & Safety.

This article originally appeared in the March 2006 issue of Occupational Health & Safety.

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