Failing to follow lockout/tagout rules can get you in trouble with OSHA, but it can also be fatal.
When OSHA compliance officers inspect a facility, they examine its lockout/tagout program, and last year the organization issued almost 4,000 citations for lockout/tagout violations, with fines totaling almost $7.7 million.
Lockout/tagout regulations can minimize or prevent electrical workplace injuries, but only if they're applied properly. If you perform maintenance work of any kind, you may need to comply with the control of hazardous energy (lockout/tagout) regulations in 29 CFR 1910.147 and 29 CFR 1910.333(b)(2). Following these rules isn't just good safety practice, it's the law.
OSHA lockout/tagout standards apply to maintenance work that exposes employees to energy hazards. Generally, you should use lockout/tagout procedures to prevent injury from energized equipment. But more specifically, use them if you:
Remove or bypass equipment guards or other safety devices, creating exposure hazards at the point of operation.
Place any part of your body in contact with the point of operation.
Place any part of your body in the danger zone of a machine's operating cycle.
Might contact parts of fixed electrical equipment or circuits. Shutting them off isn't enough to protect you.
What should an employer do to protect workers from these hazards? The standard requires employers to develop a written program that includes the following three elements:
Energy control procedures to document what authorized employees must know. If similar equipment uses the same procedures, you may use a single energy control procedure. Otherwise, develop separate procedures for each type of equipment.
Training and retraining employees so they understand the procedures.
Periodic inspections to ensure employees follow procedures.
Your lockout procedures should follow these steps:
Before shutting off equipment, the authorized employee who will perform service or maintenance must know and understand the procedures for that equipment.
Turn off the equipment using established procedures to avoid hazards from unexpected or unplanned stops.
Locate all energy-isolating devices, and isolate the equipment from its energy source(s).
Each authorized employee should add a personal lock. When more than one authorized employee performs work, use a lockout device that can hold several locks at once. If an electrical hazard isolation device will not accept a lock, you can't use just a tag; you must add an additional safety measure that provides protection equal to a lock. Examples include removing an isolating circuit element, blocking a controlling switch, or opening an extra disconnecting device.
After lockout or tagout, release all potentially hazardous stored or residual energy.
Before work begins, verify proper isolation. For electrical hazards, use electrical test equipment to verify that the circuits and electrical parts are de-energized. To ensure electrical equipment has been de-energized, you must meet — and be trained on — all “qualified person” requirements, as outlined in 29 CFR 1910 Subpart S, Electrical.
If lockout work continues to the next shift, either maintain continuous control of the energy-isolating devices or require the oncoming shift to verify de-energization and lockout/tagout. In general, if equipment is locked out at shift change, incoming employees should apply their locks before the outgoing employee removes his.
After finishing your work, follow these steps for removing devices and restoring energy:
Remove tools and other items, and make sure all components are intact and operating properly.
Remove or safely position all employees.
The authorized employee who applied the lock or tag should remove the device (see Who Can Remove a Lock or Tag? above).
Inform other employees that locks or tags have been removed before starting the equipment.
If you work with outside contractors, inform them of your procedures. They must also understand the meaning of locks or tags they encounter. If you're a contractor, inform your customer of your procedures and offer to provide training so the customer doesn't remove locks or tags. Both parties should understand and comply with all restrictions of each other's energy control program.
Do you know your responsibilities? The amount of training you need depends on your job duties. If you're in charge, it's your responsibility to make sure your employees are up to speed. Authorized employees need to recognize hazardous energy sources, understand the type and magnitude of the energy available in the workplace, and know the methods for energy isolation and control. Affected employees should understand the purpose and use of the procedures and be familiar with the equipment, types of energy, and hazards specific to the workplace. Other employees should be familiar with the procedures and trained not to restart equipment that is locked out or tagged out.
Employees shouldn't tamper with lockout/tagout devices, or attempt to energize or operate locked out equipment unless authorized.
The lockout/tagout standard requires you to provide retraining if:
An employee changes job assignments.
Machine, equipment, or process changes present a new hazard.
Energy control procedures change.
A periodic inspection gives a supervisor reason to believe an employee's knowledge or use of the energy control procedures aren't adequate.
You must certify that all of your employees covered by the standard have received training. Be sure to include each employee's name and the dates of training in the certification.
Why should you schedule periodic inspections? Employees must follow procedures and know their responsibilities. Inspections should also identify any problems that require correction. The lockout/tagout standard requires these inspections at least once a year.
Inspections for lockout procedures should include a review of each authorized employee's responsibilities. Inspections of tagout procedures should include a review on the limitations of tags with each affected and authorized employee.
Certify each audit by identifying the equipment, inspection date, employees involved, and person performing the inspection.
OSHA standards provide the minimum requirements for protecting employees. As an employer, you're responsible for developing an adequate program. But is it enough to just protect your employees adequately? Take the time to institute a comprehensive lockout/tagout program and make sure your employees are well trained in the procedures. Not only will you avoid penalties from OSHA, but you'll also have the satisfaction of maintaining a safer work environment.
Zalewski is a technical editor with J.J. Keller & Associates, Inc.
What if the authorized employee who applied the lock or tag is not available to remove it? In this case, the device may be removed under the direction of the employer if specific procedures and training for such removal have been developed, documented, and incorporated into the energy control program. The employer must:
Verify that the authorized employee who applied the device is not at the facility.
Make all reasonable efforts to contact the authorized employee before removing the device.
Make sure the authorized employee knows the device was removed before he or she resumes work.