Do you know everything you need to know about the 10 most frequently cited Occupational Health and Safety Administration standards? In this series, we’re exploring the most common OSHA violations, one by one. Keep reading to learn how to avoid a lockout tagout violation.
Lockout Tagout Definition?
OSHA definition: “The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147, addresses the practices and procedures necessary to disable machinery or equipment, thereby preventing the release of hazardous energy while employees perform servicing and maintenance activities. The standard outlines measures for controlling hazardous energies—electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources.” (Source [PDF])
Simple definition: Some machines can seriously injure or kill workers. These machines are dangerous because they are hazardous energy sources—in the form of electricity, steam, chemicals, or another kind of power.
Hazardous energy sources can release whether the machine or equipment is being used or not. This is why it’s important for dangerous machines to be completely shut off before servicing and maintenance. For example:
- A capacitor that hasn’t been properly disconnected could electrocute someone trying to repair it.
- A hydraulic press that hasn’t been de-energized could crush someone.
- A steam valve that hasn’t been bled out could scald someone.
OSHA’s Control of Hazardous Energy control programs, usually called the “Lockout/Tagout” standard (or LOTO for short), outlines what workers should do to safely depower dangerous machines. One of the main steps of a LOTO program is literally locking the machine or equipment in the “off” position and adding a tag with the name of the person who carries the key to the lock.
Why Lockout/Tagout Violations Happen
As with so many OSHA standards, lockout/tagout violations frequently come down to poor documentation. Authorized employees should have detailed, written procedures for every machine they have in use. Some organizations neglect to document certain pieces of equipment; other organizations lack written procedures entirely.
Inadequate employee protection and training is another critical risk area. Training isn’t just for workers who operate, service, or apply locks and tags to the machines. Any affected employee who works around dangerous equipment needs to undergo some level of lockout/tagout training.
Some employers violate the standard by simply failing to identify every source of hazardous energy in their facilities.
Others use the wrong lockout/tagout devices.
Still other employers don’t recognize their lockout/tagout risks because they don’t perform regular audits. OSHA requires organizations with dangerous machines to perform periodic inspection and test those machines, as well as to evaluate their LOTO procedures.
Finally, organizations sometimes fall short because they don’t follow all lockout/tagout procedures in the correct order. Typical minimum procedures require the following:
- notify employees affected
- shut down equipment
- isolate the source of energy
- attach the lockout device
- release or restrain any energy stored within the machine
- verify the lockout
What You Stand to Lose When Lockout/Tagout Violations Happen
Direct costs: OSHA penalties can exceed $13,000 per violation—and as much per day for every day the issue hasn’t been fixed by OSHA’s deadline. The fine for a willful or repeated violation can be 10 times as much.
- workers’ compensation claims from workers injured by improperly locked machinery
- lost productivity during and after an incident
- costs of replacing any equipment damaged by improper lockout/tagout procedures
- legal and compliance fees
- decreased morale
- negative publicity and reputational damage
Signs You’re at Risk of a Lockout/Tagout Violation
You work with a lot of machines: The more dangerous equipment you have in use, the higher your risk for a lockout/tagout violation.
Your equipment is old or high-maintenance: If you’re constantly servicing or fixing your machines, you’ll need to ensure continuous lockout/tagout program compliance.
Your workforce hasn’t been trained properly or consistently: Workers involved in a lockout/tagout program need specific training. The same goes for workers who perform servicing and maintenance. On top of that, everyone who works around dangerous machines should be aware of basic lockout/tagout procedures.
You can’t remember your last lockout/tagout audit: If it’s been over a year since you evaluated your equipment and procedures, you could be in trouble.
We’ve developed this brief quiz to see how your Hazard Communication Program stacks up.
How to Avoid a Lockout/Tagout Violation: Your Prevention Checklist
1. Have you identified every hazardous machine in your facility or facilities?
2. Do you have written lockout/tagout procedures in place for every machine? Procedures should include maintenance tasks or activities to machinery, including setup, installation, removal, maintenance, operation, adjusting, cleaning, troubleshooting, and programming. Procedures should also cover equipment connected to the hazardous machinery
3. Are your employees following proper maintenance and service protocol? Employees should never remove or bypass machine guards or other safety devices, place any part of their bodies in or near a machine’s point of operation, or place any part of their bodies in a danger zone associated with machine operations. Employees should check the safety of a lockout without exposing anyone else to potential hazards.
4. Have you ensured any equipment, machinery, or parts of machinery won’t unexpectedly release stored energy automatically, or due to human error? Employee protecton entails a complete maintenance tasks or activities on machinery, be sure there are no potential stored energy hazards associated with the task, such as electrical, gravitational, mechanical, chemical, thermal, pneumatic, hydraulic, or radiation. Be sure to eliminate all potential hazards due to human error as well.
5. Have you eliminated all potential for injury (burns, laceration, contusions, punctures, electrocution, crushing, etc.) or death from the hazards while completing the maintenance tasks?
6 Do employees have the correct locks and/or tags? Designated employees should have individually keyed personal safety locks, and should be required to keep personal control of their key(s) while they have safety locks in use. Only the employee exposed to a given hazard should place or remove their safety lock. Any and all employees working on locked-out equipment should be able to be identified by their locks and/or tags. Additionally, OSHA recommends a “sufficient number of accident prevention signs or tags and safety padlocks” be “provided for any reasonably foreseeable repair emergency.”
For more information and guidance about preventing a lockout/tagout violation, please contact us.