When is Lockout Tagout Required?

The purpose of lockout/tagout procedures is to control hazardous energy sources so that employees are not in danger when servicing and maintaining machines and equipment. Energy sources regulated by OSHA include electrical, chemical, pneumatic, mechanical, hydraulic, and more. OSHA standards also have requirements for when lockout/tagout is necessary for people working on electric circuits and other equipment.

When Lockout/Tagout Standards Apply

Generally speaking, anyone who performs service or maintenance on machines that could potentially cause harm must be protected by lockout/tagout procedures. In addition, when workers must install, adjust, inspect, or maintain machinery and equipment, they must be protected. Routine maintenance tasks such as lubricating and cleaning also typically require protection.

According to OSHA standards, lockout/tagout standards apply when performing any action needed to prepare, maintain, or repair a machine or equipment for normal use. There are a few exceptions to this requirement. For example, in situations where equipment that is cord or plug connected is exclusively controlled by the worker servicing the equipment. Another exception is for minor activities such as small tool changes, as long as the activities are routine, repetitive, and integral to production and other protective measures are used. 

During normal production, or when a machine is being used to perform its intended function, a few situations require lockout/tagout procedures to be used. For example, if a worker must remove or work around the required machine guarding, the machine must be shut down and locked/tagged out. 

Critical OSHA Hazardous Energy Requirements

OSHA standard number 1910.147 outlines all requirements regarding sudden energization or unexpected startup of equipment and machines, or the unexpected release of stored energy, that could harm employees. Every operation should understand the full text of these requirements thoroughly or engage a machine safety consultant who can perform a safety audit.

The main requirements that will apply to nearly all applications include:

• Establish a Program. Every employer is responsible for developing, implementing, and enforcing a program for hazardous energy control when it is applicable. This program and its procedures must be inspected at least once per year. 
• Use Lockout Devices. For all equipment that can be locked out, a lockout device must be used. Tagout devices can only be used when lockout is not possible, and only when a tagout device provides the same level of protection as lockout. 
• Use Appropriate Devices. Only devices authorized for the specific machine or equipment may be used, and devices must be standardized, substantial, and durable. In addition, lockout/tagout devices must identify the individuals using them. 
• New Equipment. When new equipment is installed, or existing machinery is updated, it must be equipped with lockout capabilities. 

The Minor Servicing Exception

OSHA’s Lockout/Tagout standards are not meant to cover minor servicing procedures necessary for completing the production process as long as all associated dangers are properly guarded. For this exception to apply, the following conditions must be met:

• The procedures must be done during normal production operations, or while the equipment is performing its intended function.
• The procedures must be routine, or a regular part of the procedure; repetitive, or regularly repeated during production; and integral, or critical to the process of production.
  If these conditions are met, alternative means of protection from hazardous energy must be provided. In these cases, Subpart O of OSHA standard number 1910.147, which references machine guarding, should be consulted. 

Typical Lockout/Tagout Procedures

The purpose of lockout/tagout is to ensure that machinery and equipment are completely inoperable during maintenance or repair work. In addition to locking the machine from operation, procedures must also include steps to prevent others from engaging with the equipment. 

The specific devices used to achieve this vary depending on the specific equipment and operation. There are also kits, software packages, and other tools to assist in managing these procedures. Regardless of the method, these are the steps that every operation should follow:

1. Preparation. The first step includes the authorized worker identifying and understanding the specific hazards present and the policies present for controlling these dangers. Any employees who may be affected by the shutdown should also be notified. 
2. Shutdown. Once the preparation is complete, power down the machine.
3. Isolation. The machine or equipment being serviced must be isolated from any source of energy by turning off power at the breaker or other isolation measures. 
4. Lockout/Tagout. Lockout or tagout devices are applied to each of the devices used to isolate the equipment from energy sources. 
5. Stored Energy Check/Discharge. Equipment must be inspected for stored or residual energy that must be disconnected, relieved, or otherwise made safe. 
6. Isolation Verification. The last step is always to verify that the machine is properly isolated from all power sources and de-energized. 

What Workers Need to Know

All workers must be trained to understand and follow all the procedures for maintaining safety during maintenance and repairs. OSHA stipulates that training must be provided to all employees to explain all aspects of the energy control program. They must learn each of the elements that are relevant to the employee’s responsibilities, and what OSHA requirements are regarding lockout/tagout standards. 

OSHA also states that both affected and authorized employees understand their roles during a lockout/tagout. An authorized employee is the one who places the lock or tag, and they are the one who is performing work on the machine or equipment. Affected employees are those who work in the area where service is taking place, or whose duties include operating equipment that is receiving service and is locked or tagged out.

Authorized employees must notify affected employees when lockouts and tagouts are placed and when they are removed. Only the authorized employee may remove locks or tags, and affected employees must be aware of this procedure.

Safety First

The best time to consider safety procedures is before an accident happens. On-the-job injuries resulting from exposure to hazardous energy lead to an average of 24 workdays for recovery every year. It is the responsibility of employers to protect their workers from dangerous energy sources while servicing and maintaining equipment. Lockout/tagout procedures are estimated to prevent 120 fatalities and up to 50,000 workplace injuries every year. 

To ensure your workers are protected, a third-party equipment and machine safety consultant can help. Choose a partner who understands OSHA requirements and has the proper experience to perform a safety audit and provide recommendations to keep you compliant.

Is your company struggling and in need of support? Our case study demonstrates the value of risk assessment in avoiding employee injuries. We have the resources and expertise to assist.