8 Steps to Increase Safety and Strengthen Your LOTO Training Program

Preventing injury and loss of life is undeniably the number one reason to strengthen any safety program. 

• By JoAnn Mrgich, Colwin Chan
• Aug 02, 2021

Crushed, fractured or amputated limbs, electric shock, explosions and heat/chemical burns—these are just some of the dangers workers face when stored energy is unexpectedly or accidentally released. Stored energy is found in nearly all sectors of industrial business, and when it’s not properly controlled, it can easily result in serious injury or loss of life. Controlling stored energy such as, electricity, kinetic energy, thermal energy, pressurized liquids and gases is critical to keeping workers safe. The best way to help your team safely work with stored energy is to ensure you have a strong lockout/tagout (LOTO) training program for controlling hazardous energy.

Business Benefits of Strengthening Your LOTO Program

Preventing injury and loss of life is undeniably the number one reason to strengthen any safety program. However, there are also concrete business benefits, for example, according to the National Safety Council (NSC) Injury Facts report online, work injuries cost employers $171 billion dollars and $105 million days lost in 2019 alone.

Strengthening LOTO training specifically, helps reduce the chance of costly OSHA fines for serious violations (i.e. injury or death) which start at $13,653 per violation. LOTO infractions routinely make the annual list of most common OSHA violations, coming in sixth during the 2020 fiscal year. Additionally, strengthening your LOTO program will include standardization. Standardizing any process increases efficiency. The time/resources you spend codifying and organizing your LOTO training program will be rewarded with time/resources saved over time with more efficient processes in place.

Step 1: Identify Authorized, Affected and “Other” Employees

Authorized employees and affected employees require different levels of LOTO training and retraining. The first step to strengthening your program is to identify authorized and affected employees so that you can ensure each team member is receiving the proper training.

Authorized employees. Anyone who locks out or tags out machines/equipment in order to perform service or maintenance must receive LOTO training to become authorized. Employees become authorized after receiving LOTO training for applying, using and removing energy controls. 

Affected employees.  Anyone who operates or services machines/equipment that require de-energizing for safe maintenance, or works in “an area in which such servicing or maintenance is being performed.” (OSHA 1910.147b)

It is important to note here that affected employees can be re-categorized as authorized employees (and thus require authorized-employee training) if their duties change to include service/maintenance of machines/equipment that require de-energizing.

“Other” employees.  Anyone who does not fall into the authorized or affected category, but whose work may require them to be in an area where lockout/tagout is performed.

Step 2: Review OSHA Requirements for LOTO Training

LOTO training requirements are covered in OSHA standard 1910.147, The Control of Hazardous Energy. This standard is also referred to as the LOTO standard or lockout/tagout standard interchangeably. Following regulation 1910.147(c)(7)(i)(A), authorized employees must be trained on the following: 1) recognition of applicable hazardous energy sources, 2) details about the type and magnitude of the hazardous energy sources present in the work area and 3) the methods and means necessary to isolate and control hazardous energy sources.

Affected and “other” employees are covered under 1910.147(c)(7)(i)(B) and 1910.147(c)(7)(i)(C), respectively. Affected employees must be trained to understand the purpose and use of energy control procedures. All other employees working nearby must be instructed about the procedure and the fact that it’s prohibited to restart or reenergize any machine/equipment that is locked out or tagged out.

Step 3: Get Procedures Down on Paper

Written lockout/tagout procedures are a must. OSHA 1910.147(c)(4)(i) specifically mandates those procedures “be developed, documented and utilized.” Clearly documented safety procedures also make it easier for employees to learn and follow protocols. Storing a copy of LOTO procedures in a heavy-duty binder makes them easily accessible to employees as well as inspection officers.

Digital records are great for saving space but can be difficult to access. If you do choose to store procedures digitally, consider displaying barcode labels for digital access in high-traffic employee areas. Using label design software, you can easily create your own QR barcodes that link to information online. Anyone with a smartphone can use a QR code to instantly go to the link.

Step 4: Standardize Training Materials and Organize

1910.147(c)(5)(ii)(B) requires both lockout and tagout devices to be standardized within a facility. This includes shape, size or color for locks, print and format for tags. Standardization is important in safety procedures because it makes dealing with known hazards routine and easier for employees to recognize on sight. Applying the same principles of standardization and keeping training materials organized can also help strengthen LOTO safety in your facility.

First, clearly identify training materials for authorized, affected and “other” employees to ensure that the right information is getting to the right people. Use standardized labels, color-coded binders or dividers to make it easy for employees to quickly navigate to the information they need. Next, make sure training information is not only accessible but digestible. Well-organized materials allow you to provide much more information for employees in a wide variety of formats. Training materials that range from white papers and your full company policy for controlling hazardous energy, to short OSHA handouts or links to videos online, accommodate a wider variety of learning styles. The more resources available to your team, the more knowledgeable they become, increasing LOTO safety in your facility.

Step 5: Streamline Training Records

1910.147(c)(7)(iv) requires employers to certify that training has been completing and is being kept up to date with certification records that contain each employee’s name and the dates of their training. Whether you store LOTO training records physically or digitally, it’s a good idea to standardize a system for separating records for authorized, affected and “other” employees. Keeping your records streamlined and organized will help save time during OSHA inspections as well as in-house inspections and/or retraining. If you’re storing records physically, ensure that you use heavy-duty binders, sheet protectors and plastic dividers that will not degrade in an industrial setting.

Step 6: Reinforce Best Practices and Training Basics

Provide visual tools to help your team stay vigilant. For example, posters, safety signs, labels and tags that reinforce best practices, training basics and protocols that are unique to your facility. Every authorized, affected and “other” employee working with machinery/equipment that stores hazardous energy should know the six steps of LOTO safety by heart. These include: 1) preparation for shutdown, 2) shutdown, 3) isolation, 4) place lockout/tagout devices, 5) release stored energy and 6) isolation verification.

Safety posters featuring the six steps of LOTO safety and other LOTO training procedures specific to your facility are a great way to help workers commit important information to long-term memory and/or review daily as needed.

Step 7: Conduct Periodic LOTO Inspections

LOTO inspections are covered under OSHA 1910.147(c)(6) and require that an authorized person inspects the facility’s total energy control/lockout tagout procedures at least once a year. However, it’s considered best practices to conduct an inspection in the following instances: 1) after retraining has occurred or 2) if you suspect procedures are not being followed.

During lockout/tagout inspections, OSHA requires the following:

• All procedures for each machine/piece of equipment must be inspected
• Employees cannot inspect themselves
• All authorized and affected employees must be reviewed (however this can be done as a group as OSHA does not require one-on-one inspections)
• The employer must certify that the inspections have been done
• Certification must identify the machine/equipment and include the procedure, the date, the employees involved and the person who performed the inspection

Step 8: Facilitate (and Record) Retraining as Needed

1910.147(c)(7)(iii) covers retraining employees in LOTO safety. At minimum, retraining must occur when: 1) there is a change in job assignments for authorized or affected employees, 2) a change in machines, equipment or processes present a new hazard or 3) there is a change in energy control procedures.

OSHA also mandates that additional retraining must be given to employees “whenever the employer has reason to believe that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures.” This can happen after a routine inspection or any time the employer has any reason to question the employee’s proficiency.

Employers must certify LOTO retraining in the same manner as regular LOTO training (i.e. including the employee’s name and the dates of their training). Use the same record management procedures for training and retraining certification to increase standardization and efficiency.

Benefits of Strengthening LOTO Training

Whether you’re building your LOTO training program from scratch or updating your current program, a few key fundamentals make all the difference. Identify employees to ensure the right people get the right information. Document, standardize and organize the specific lockout/tagout procedures in your facility, certification records, inspection records and training materials. Reinforce best practices and conduct regular inspections to keep everything on track.

This article originally appeared in the July/August 2021 issue of Occupational Health & Safety.