Every year, thousands of workers are injured or killed because of contact with hazardous energy. This typically happens during equipment maintenance because lockout/tagout (LOTO) procedures were not in place or properly followed [29 CFR 1910.147].
In fact, violations of the LOTO standard have been an Occupational Safety and Health Administration (OSHA) top ten violation for the past decade. OSHA issued more than 3,000 citations in 2015 alone to companies who had poor or no hazardous energy control procedures, inadequate employee training or undocumented inspections.
Each of these elements (energy control procedures, employee training and periodic inspections) make up a complete LOTO program, and without even one of these elements, you’d be violating the LOTO standard and putting employees at risk.
The point of a LOTO program is to create a plan and train employees on how to prevent a surge of hazardous energy during equipment maintenance. OSHA doesn’t specify a format for LOTO programs, but does require that you include the three following elements [29 CFR 1910.147(c)]:
1. Energy Control Procedures
After identifying the machines and equipment that pose a hazardous energy risk, employers must develop procedures for:
- Authorizing employees to use appropriate lockout devices
- Relieving or disconnecting hazardous stored energy and verifying safety before maintenance or servicing begins
- Disabling machines or equipment to prevent unexpected energization, as well as removing LOTO devices after they have been serviced or maintained
- Documenting the “durable,” “standardized” and “substantial” hardware (locks, tags, chains, etc.) that will be used for isolating, securing or blocking off machines or equipment from energy sources
- Identifying how employees will be notified of use and removal of lockout devices, including: preparation for shutdown, machine or equipment shutdown and isolation and applying and removing LOTO devices
Employers must also make provisions for safeguarding outside contractors, create procedures for any group lockouts and document a process to ensure safety during shift and personnel changes.
2. Employee Training
Plans must document that employee training includes:
- The purpose and function of the program
- Sources of hazardous energy in the facility and the hazard potential of each item
- Procedures to be followed for isolating machines and equipment that will be maintained or serviced, including application, use and removal of LOTO devices
- Prohibitions of disabling machines and equipment that has been locked or tagged out
- The limits of tagout systems, if used
Employees must be retrained if their job assignments change, when procedures change and when there are changes in machines or equipment. Employers must also verify and document each employee’s proficiency and retrain personnel if they find that plans are inadequate or that employees are deviating from established procedures.
3. Periodic Reviews
Plans must be reviewed at least annually and must:
- Be conducted by someone other than the person who utilizes the procedure
- Identify affected machines and equipment
- Correct any inadequacies or deviations that are found
- Review employee responsibilities if tagouts are used to control hazardous energy
Documentation of these inspections needs to be kept indicating the dates of the inspections, employees who participated in the inspections, what procedures were utilized and who performed the inspection.
Maintaining and servicing machinery and equipment is a reality that nearly every facility faces. Establishing a LOTO plan and training employees to avoid the potential risks caused by uncontrolled hazardous energy sources will help reduce and prevent the more than 50,000 injuries and fatalities that occur each year when machines and equipment are not properly guarded during repairs.
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