When is Lockout Tagout Required?

Workplace safety is a continual concern and a frequent topic of discussion in all industrial and manufacturing environments. Establishing proper procedures and ensuring that all workers are trained and comply with safety procedures is critical. Lockout tagouts have ensured that dangerous equipment is de-energized correctly in the United States for several decades.

What Exactly is Lockout Tagout and Why Does It Matter?

Lockout tagout controls hazardous energy sources so 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 require lockout/tagout when it is necessary for people working on electric circuits and other equipment.

What is Meant by Lockout Tagout?

Lockout tagout (LOTO) is a safety procedure used to ensure that dangerous equipment is shut down and safe for maintenance and repair work. Lockout refers to hazardous energy sources that must be rendered inoperative and locked by the person who will work on the equipment. Tagout refers to a tag placed on the lock to identify who placed the lock and why.

What Are the Basics of Lockout Tagout?

The purpose of LOTO procedures is to ensure equipment is de-energized before a worker enters a dangerous area. The second consideration is that the equipment cannot be energized and started up again by accident or by anyone other than the person who placed the lock and tag. For that reason, the worker keeps the key for the lock with them.

The devices used to achieve this vary depending on the specific equipment and operation. Kits, software packages, and other tools also assist in managing these procedures.

Lockout Devices

Padlocks are the most common device for ensuring secure energy isolation points. A LOTO padlock functions much like an ordinary one, but it is designed for lockout purposes and must stand out from an ordinary lock. A LOTO padlock should have only one key, and each lock should have a unique one.

Several types of devices can also be used in conjunction with a LOTO padlock to ensure that switches and valves remain in an “off” or inoperable position. For example, ball valve or gate valve lockouts are designed to physically cover valves to prevent their operation, and a padlock is placed on the lockout device.

Cable lockouts are flexible and can be wound around handles or gate valves and secured with a padlock. Pneumatic lockouts prevent fittings from being connected to a pressurized air source, preventing machinery from operating.

Lockout hasps and group lockout boxes are used when multiple people are servicing the same equipment. Both allow multiple padlocks to be used to account for each worker before re-energizing dangerous equipment.

What are the 7 Steps to Lockout Tagout?

Every lockout tagout operation should follow these steps:

1. Preparation. The first step involves the authorized worker identifying and understanding the specific hazards and the policies for controlling these dangers.
2. Notification. Any employees affected by the shutdown should be notified of which equipment will be powered down, the reason, the estimated time frame, and who to contact for questions.
3. Shutdown. Once the preparation is complete, power down the machine according to the manufacturer’s or workplace procedures and ensure all moving parts have come to a full stop.
4. Isolation. The machine or equipment being serviced must be isolated from any energy source by turning off power at the breaker or other isolation measures.
5. Lockout/Tagout. Lockout or tagout devices are applied to each device used to isolate the equipment from energy sources.
6. Stored Energy Check/Discharge. Equipment must be inspected for stored or residual energy disconnected, relieved, or otherwise made safe.
7. Isolation Verification. The last step is always to verify that the machine is properly isolated from all power sources and de-energized.

The Importance of Lockout Tagout for Keeping Workers Safe

Generally speaking, anyone who performs service or maintenance on machines that could potentially cause harm must be protected by lockout/tagout procedures. In addition, workers must be protected when installing, adjusting, inspecting, or maintaining machinery and equipment. 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 everyday use. During normal production or when a machine is being used to perform its intended function, a few situations require lockout/tagout procedures. For example, if a worker must remove or work around the required machine guarding, the machine must be shut down and locked/tagged out.

Spotting Dangerous Energy Sources in Your Workplace

The OSHA standard for the Control of Hazardous Energy (29 CFR 1910.147) outlines all requirements regarding sudden energization, 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 the services of a company that 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. A lockout device must be used for all equipment that can be locked out. Tagout devices can be used alone only when a lockout is not possible and only when a tagout device provides the same level of protection as a 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, existing machinery is updated, or during commissioning, it must be equipped with lockout capabilities.

OSHA Violations

The average OSHA penalty for a lockout tagout violation is over $6500; some violations have reached over $70,000. The most common citations are issued for failing to shut down, de-energize, or drain residual energy from equipment. Other common violations include:

• Failure to create equipment-specific lockout tagout procedures.
• Failure to provide adequate training.
• Failure to conduct periodic testing and inspection of lockout tagout procedures.
• Failure to enforce a lockout tagout policy.

While OSHA penalties can be steep if violations are found, the penalties can be far worse if an audit is performed as the result of an injury in the workplace. Creating, maintaining, and educating workers on safety procedures can take time and resources; however, the expense and unexpected shutdowns from injuries or equipment damage far surpass the inconvenience of preventive safety inspections.

How to Make Sure You’re Following Lockout Tagout Guidelines

All workers must be trained to understand and follow all the procedures for maintaining safety during maintenance and repairs. OSHA stipulates that all employees must be trained to explain all aspects of the energy control program. They must learn each of the elements 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 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.

Real-Life Scenarios Where Lockout Tagout is a Must

One of the most critical scenarios for lockout tagout procedures is when workers must enter areas with moving machine parts or reach into machines to remove or repair damaged parts. These can include robotic arms, grinding equipment, belts, rollers, and more.

Any time electrical work must be performed, lockout tagout is also necessary. From scheduled repairs and inspections to unexpected repairs, all energy sources must be contained before any work can be done.

The Quad Plus team was recently called out to a consumer goods company after an OSHA audit was performed following an injury to one of their workers. In this case, the machine had two turreting mandrels that allowed operators to unload a finished roll while the other continued to wind.

Removing a finished roll was a dangerous procedure, as the rolls were relatively close to each other, exposing workers to a draw-in hazard. A pneumatic slice knife and the potential of being crushed by a finished roll also presented hazards.

When followed properly, the customer’s lockout tagout procedure for this operation kept workers safe. However, we discovered that the protocol was not always followed because it was cumbersome and time-consuming. Our experts implemented several automated solutions, including a muting zone that cannot be bypassed by rushing workers.

Are There Times When Lockout Tagout Isn’t Needed?

There are a few situations where the LOTO standards do not apply. The first is equipment that is de-energized by unplugging a cord from an electrical outlet, and the person working on the equipment has complete control of the plug. Another exception is 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.

Hot-tap operations on pressurized pipelines are also excluded from LOTO requirements when shutting the system down is impractical and when continuity of service is essential. In this case, workers must follow documented alternate procedures that provide adequate protection.

Certain agriculture and maritime operations, as well as oil and gas well drilling and servicing, are excluded from lockout tagout procedures.

Safety First

The best time to consider workplace safety procedures is before an accident happens. On-the-job injuries resulting from exposure to hazardous energy require an average of 24 workdays for recovery every year. Employers are responsible for protecting 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 annually.

A third-party equipment and machine safety consultant can help ensure your workers are protected. Contact Quad Plus for a partner who understands OSHA requirements and has the proper experience to perform a safety audit and provide recommendations to keep you compliant and your workers safe.