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How to Avoid Putting Your Lockout/Tagout Program at Risk

June 15, 2023
Avoid these four problem areas to keep your workers safe from electrical energy hazards.

Thanks to advancements in technology, manufacturers are increasingly using computer-based controls in their equipment and machines. These can be programmed to lock out the machine or equipment. This is necessary during minor repairs and servicing because they require constant energization. Built-in technology can help prevent and reduce electrical injuries and fatalities by designing out electrical hazards and risks.

Over the last few years, the Occupational Safety and Health Administration (OSHA) has also been exploring whether modern technology can effectively protect workers from hazardous energy.

OSHA issued a Request for Information (RFI) in May 2019 to understand the strengths and limitations of this new technology as well as the potential hazards to workers. The comment period ended in August 2019. In the years since, employers continue to wait patiently, anticipating OSHA’s Advance Notice of Proposed Rulemaking (ANPR) on the issue. Meanwhile, employers continue to deal with four lockout/tagout (LO/TO) problem areas.

Like most OSHA regulations, the Control of Hazardous Energy (lockout/tagout) standard (§1910.147) uses common sense principles to protect employees. To ensure safe work, the standard requires written energy control procedures, employee training and periodic inspections. However, four problem areas cause quite a bit of confusion:

  • Applying the “minor servicing” exemption,
  • Using a single energy control procedure for multiple machines,
  • Training for work that involves electrical hazards, and
  • Periodic inspections for multiple control procedures.

Let’s explore these further so you can learn how to keep workers safe from electrical energy hazards. I will also share real-world examples of LO/TO done right—and wrong.

1. Minor Service vs. Lockout Procedure

The standard includes a minor servicing exception that allows for certain maintenance work without using LO/TO where these tasks can be done safely. Examples might include clearing jams, applying lubrication or replacing a worn belt.

To qualify for the exception, the work must:

  1. Take place during normal production operations;
  2. Be routine, repetitive and integral to the use of the equipment for production; and
  3. Be performed using alternative measures, such as machine guards, that provide effective protection.

If a maintenance task does not meet all three criteria, it is not exempt. Employers often assume that a task is exempt when it requires lockout procedures. Clearing a jam might be a normal part of production, but if doing so puts an employee at risk or requires removing or bypassing fixed guards, it probably does not qualify for the exemption.

A common violation involves work that exposes the employee to hazardous energy or points of operation. Sadly, this discovery is often made when an employee gets injured, possibly losing a finger—or worse.

To avoid the lockout/tagout requirements during minor service, you must protect employees using guards or other measures that allow them to safely perform the service without being exposed to hazardous energy. Review any routine maintenance work to verify that it meets the exemption. If workers perform regular service that does not meet all three criteria, you need to develop LO/TO procedures.

Case Study: A maintenance worker was servicing manufacturing equipment under the minor service exception. While lubricating the equipment and removing a jam, the worker bypassed the fixed guard without using an alternate form of protection. The equipment’s internal parts moved and pinched the worker’s hand between parts. As a result, he was severely injured. The worker didn’t have any alternate form of protection in place.

2. Using One Procedure for Multiple Machines

Much of the time, you need to develop a unique procedure for each machine. But sometimes, similar machines often use similar energy control procedures, and a single procedure can work for more than one machine. In these instances, a generic energy control procedure with supplemental checklists can meet the OSHA standard.

Machines or equipment that use the same type and magnitude of energy—and that have the same or similar controls—can be covered with a single procedure. However, the procedure must include enough detail and provide enough direction so employees can follow it and safely perform their work. If the procedure is too generic, it will not be useful.

To be covered by one procedure, the machines or equipment must have the same:

  • Specific procedural steps for shutting down, isolating, blocking and securing them to control hazardous energy;
  • Specific procedural steps for the placement, removal and transfer of lockout/tagout devices and the responsibility for them; and
  • Specific requirements for testing to determine and verify the effectiveness of lockout/tagout devices and other control measures.

Although you can use one set of procedures for multiple machines, the procedure must provide instructions that specify a step-by-step approach for each machine. OSHA will carefully examine the procedure of any employer that claims only one procedure is adequate. If you have multiple machines that use the same procedure, verify that the above criteria are met to ensure compliance and to protect your workers.

Case Study: Guideway workers radioed to the control room operator to have a maintenance technician de-energize power to the train track and lock out the switches with an energy-isolating device (EID). The transit agency had one LO/TO procedure for all electrical switches in the facility. The maintenance technician followed the procedure and could lock out a primary switch but not a secondary one because it was different and didn’t have a place to affix an EID. The technician placed a sign on the switch saying “Do Not Operate.” The sign fell off, and another worker energized the switch accidentally, causing the guideway workers to get shocked. 

3. Training to Handle Electrical Hazards

Workers who perform lockout/tagout require training as authorized employees under the standard. However, an authorized employee cannot verify that an electrical circuit is de-energized. Doing so requires training as a qualified person under the Electrical Safety-Related Work Practices standard. The training requirements can be found in §1910.332. The definition of a qualified person notes that whether a person is qualified depends on the circumstances and the equipment involved. It is possible for an individual to be “qualified” on certain equipment in the workplace, but “unqualified” on other equipment.

If you have workers who face electrical hazards during servicing or maintenance, ensure they have training as required by the electrical safety standards. Training as an authorized employee under the LO/TO standard is not sufficient when electrical energy is a hazard. Under LO/TO, an authorized employee is controlling hazardous energy but if work must be performed while live power is present, additional electrical safety training is necessary to ensure the authorized employee is qualified to do so.

For instance, the electrical standards require that a qualified person verify, using test equipment, that the circuit elements and equipment parts have been de-energized (see §1910.333(b)(2)(iv)).

The energy control procedure for equipment with electrical hazards should include steps to safely lockout all energy sources. However, the electrical safety regulations require a qualified person to verify that the equipment is de-energized.

Case Study: A millwright assigned to a maintenance task on an overhead crane turned off the crane’s electrical switch and placed his lock on it. However, the lever was corroded, allowing it to move to the “off” position while the stub inside the electrical box remained in the “on” position. The employee did not verify that the electricity was off. When he came in contact with the exposed energized parts, he was electrocuted. This repairman was trained as an authorized employee, but he was not trained as a qualified person.

4. Inspecting Groups of Procedures

The lockout/tagout standard requires periodic inspections of each energy control procedure, at least once a year. As noted above, sometimes a single procedure covers multiple machines. The next step is to determine whether a single audit will meet this requirement, or if you need multiple audits for each variation.

OSHA, in a Letter of Interpretation dated March 9, 2004, stated that you could group related procedures for similar equipment when conducting inspections. Grouping procedures are allowed if all procedures in the group have the same or similar use and follow the same procedural steps. In other words, if you use one procedure for multiple machines, as described above, you can treat this as one procedure for your annual or periodic inspection.

If you categorize machines and equipment, you must inspect a representative number of authorized employees performing the procedure within each category. The sampling must reasonably reflect plant maintenance operations and energy control practices for the procedure being inspected. If you group procedures, select different machines from the group for evaluation each year. This way, over time, each individual machine will eventually be inspected.

Case Study: A manufacturing facility has 130 lockout/tagout procedures. Many are unique and apply to specific equipment. Others are duplicates of nearly identical equipment. The employer only performs a periodic inspection of each of the unique energy control procedures.

The employer’s inspector observes the actual use of each unique procedure by several different authorized employees. The inspector also reviews each procedure with all authorized employees and discusses their responsibilities. The facility does not need to inspect all 130 lockout procedures because many of them can be grouped together.

The Difference between Injuries and Going Home Safely

Not following these often-misunderstood provisions of the lockout/tagout standard could put your employees at risk. Proper training, safety procedures and safety inspections can help you prevent accidents and keep your employees safe.

Employers and workers tend to understand more common safety hazards under the LO/TO standard, but these other issues are often perplexing. Don’t forget to turn your attention to these issues and ensure that your energy-control procedures address them. Ignoring them could mean the difference between being severely injured and getting home safely.

Ray Chishti, J.D., is a workplace safety editor for J. J. Keller & Associates Inc., a provider of workplace safety and regulation compliance products and services. Previously, Ray worked as an EH&S professional in auditing, management and executive leadership positions with new construction, existing facilities and large engineering, procurement and construction (EPC) projects valued between $1 million and $2 billion. He has over 19 years of EH&S experience in various industries, including fossil fuel power plants and utility distribution and transmission work. Ray’s experience includes safety responsibilities in retail grocery stores, warehouse facilities, and college campus construction. Ray is also an OSHA-authorized trainer for general industry and construction and has first aid, AED and CPR certifications.

About the Author

Ray Chishti

Ray Chishti, J.D., joined J. J. Keller & Associates Inc., a provider of workplace safety and regulation compliance products and services, in 2017 as a workplace safety editor. Previously, he worked as an EH&S professional in auditing, management and executive leadership positions with new construction, existing facilities and large engineering, procurement and construction (EPC) projects valued between $1 million and $2 billion. He has over 19 years of EH&S experience in various industries, including fossil fuel power plants and utility distribution and transmission work. His experience includes safety responsibilities in retail grocery stores, warehouse facilities, and college campus construction. He is also an OSHA-authorized trainer for general industry and construction and has first aid, AED and CPR certifications.

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