OSHA’s Top 10 List of Most Frequently Cited Standards: Control of Hazardous Energy (lockout/tagout)
Original Article: EHS.com
Employees servicing or maintaining machines or equipment are at risk of life-altering injuries or death if proper procedures aren’t in place to prevent hazardous energy from being released. This standard is about expecting the unexpected and ensuring safeguards and controls are in place to ensure those working on or with machines or equipment are not at risk of potentially fatal injuries such as electrocution, burns, crushing, fractures, amputation, etc.
Simply put, the purpose of OSHA’s LOTO Standard is to prevent injury to workers servicing and/or maintaining equipment due to the unexpected energization, startup, or release of stored energy in machines and equipment.
The LOTO Standard specifically addresses hazardous energy sources such as:
Electrical
Mechanical
Hydraulic
Pneumatic
Chemical
Thermal
Other energy sources
OSHA’s Control of Hazardous Energy (1910.147) Overview
The OSHA LOTO Standard requires employers to have an established energy control program. This consists of having documented energy control procedures, employee training, and periodic inspections. The LOTO program aims to ensure that before service and maintenance are performed, machines and equipment that could unexpectedly start, become energized, or release stored energy are isolated from an energy source(s) and rendered safe. This is generally done by de-energizing machines and equipment and then using the appropriate lockout and/or tagout devices to prevent accidental release of energy.
A lockout device physically prevents the operation of a machine or equipment by securing energy isolation points and preventing startup. A tagout device is a warning tag attached to energy isolation points indicating that employees should not operate the machine or equipment. The employer must follow a formal process before any employee removes these devices.
Employers must have rigid practices and procedures in place to ensure these energy sources are “isolated and rendered inoperative” before work is started and that those procedures are followed by all employees working with this equipment.
LOTO Requirements
There are many different requirements, clearly outlined, within OSHA’s LOTO Standard. Starting with documented energy control procedures, employers must develop, document, and use specific procedures to control potentially hazardous energy when employees are servicing equipment or machinery.
The specific elements that the employer’s LOTO procedures must include, as required by OSHA, are a summarization of the scope, purpose, authorization, rules, and techniques that the employer will use to control hazardous energy and the means to enforce compliance.
At a minimum, the procedures must include:
A specific statement of the intended use of the procedure
Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy
Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices and a description of who has responsibility for them
Specific requirements for testing a machine or piece of equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures
A LOTO training program is another critical component. Employers are required to train each employee working on the equipment to ensure that they know, understand, and can follow the applicable provisions of the hazardous energy control procedures.
The training must cover at least three areas:
The employer’s energy control (LOTO) program
Energy control procedures specific to the employee’s work duties or assignment
Other requirements of the OSHA standards related to LOTO
A third component of a LOTO program is periodic inspections. OSHA has a minimum requirement for annual systematic reviews to ensure procedures and policies are effective and being followed. The regular inspections must have at least these components:
An assessment of each energy control procedure
A review of each employee’s responsibilities under the energy control procedure being inspected
However, the LOTO program should be reviewed and updated as often as necessary to account for installing new equipment or control devices, new operators, or any other factors that could introduce potential exposures to hazardous energy sources.
What Are the Top LOTO Citations
There are many individual provisions within OSHA’s LOTO Standard, and in 2022, there were 2,139 citations issued by OSHA. Among these provisions, the top five violation types were:
1910.147(c)(4)—Energy control procedure, 638 citations
1910.147(c)(7)—Training and communication, 434 citations
OEL Low Voltage & High Voltage Training Classes (October 9th & 10th 2023 | Denver, CO)1910.147(c)(6)—Periodic inspection, 338 citations
1910.147(c)(1)—Energy control program: “The employer shall establish a program consisting of energy control procedures, employee training, and periodic inspections to ensure before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.” 199 citations
1910.147(c)(5)—Protective materials and hardware, 63 citations
Interestingly, the top four of the five most commonly cited provisions of the LOTO Standard all relate to the LOTO program requirements we listed above, suggesting that many violations are rooted in failing to establish and maintain a well-documented LOTO program.
What Are the Costs of LOTO Violations
According to OSHA, compliance with the LOTO Standard prevents 120 fatalities and 50,000 injuries yearly. Unfortunately, in the last year, around 30 deaths involving LOTO program failures were reported to OSHA. Plus, employees injured from exposure to hazardous energy lose an average of 24 workdays for recuperation.
One fatal incident at a compost manufacturing facility in Washington state in 2020 demonstrates the importance of the LOTO Standard. On the morning of the incident, a lead operator and his assistant were operating a biomass screening system that uses a stacker conveyor to deposit finished compost into stockpiles. When the assistant noticed that plastic debris was escaping from a waste container near the stacker, he went to get a leaf blower to clean up the debris and returned to find that the stacker had been shut down.
When he investigated what caused the stacker to stop operating, he saw the lead operator stuck inside the machine. The operator had tried to manually clear debris without first shutting the engine down, and the hood of his jacket got caught in the rollers, pulling him into the stacker. Employees freed the lead operator from the machine, but he died after nine days on life support. Subsequent investigations found that the company lacked a specific LOTO procedure for the stacker, which would have certainly reduced the likelihood of identifying and controlling particular risks associated with the equipment.
One fatality is too many, so it is vital to understand and comply with OSHA’s LOTO Standard. Compliance means having a detailed, well-documented equipment-specific LOTO procedure in place that identifies what equipment is being isolated, when it’s being isolated, where the equipment is located, why this equipment is being isolated, who is performing the isolation, who will be approving the isolation—and have that LOTO procedure linked to a permit-to-work process to ensure the employee performing the isolation has been trained and qualified on safe LOTO procedures.
LOTO Resources
OSHA’s LOTO Standard might seem straightforward, but as you can see from the story above, simple steps can easily be missed. Thankfully, OSHA has developed numerous tools and resources to help you safeguard employees from hazardous energy releases.
OSHA also has a LOTO eTool interactive training program that summarizes the key components of the standard in a question-and-answer format. It’s intended as a guide for understanding aspects of the LOTO Standard but is not a substitute for LOTO training program compliance.
