Lockout/Tagout (LOTO) Overview

LOTO Overview

• Lockout/Tagout (LOTO) is a technique to prevent the release of hazardous energy during equipment servicing.
• Locks are placed on energy isolation devices before starting work.
• The OSHA standard for LOTO is 1910.147.
• The Hilgeman Group specializes in industrial safety and LOTO services across North America.
• LOTO services include written programs, machine-specific procedures, training, and audits with certifications.

Hazardous Energy Types

• Types of hazardous energy include electrical, pneumatic, hydraulic, mechanical, thermal, chemical, radiation, steam, spring-driven, and suspended parts (gravity).
• Some energy sources can be turned on/off, while others must be dissipated or controlled.
• Potential energy can be converted to kinetic energy.
• Goal of LOTO is to achieve a "Zero Energy State".
• Safety blocks may be required to prevent movement of machine parts.
• LOTO is required during the servicing of equipment such as adjusting, inspecting, modifying, replacing parts, tool changes, clearing jams, lubricating, and cleaning.
• Energy isolation devices physically prevent the transmission or release of energy Examples include electrical disconnect switches, breaker switches, hydraulic and pneumatic valves, and line valves.
• Pushbuttons, selector switches, etc are NOT energy isolation devices.

Employee Roles

• Authorized Employee: Services equipment and is authorized to apply LOTO, examples include maintenance personnel, machine operators, etc.
• Affected Employee: Operates or uses equipment that may require servicing, examples include machine operators.
• Other Employee: Works in an area where LOTO is being used, examples include supervisors, inspectors and quality control associates.

Injury Statistics

• A 2016 OSHA study showed that 70% of lockout/tagout-related injuries are due to failure to LOTO equipment.

LOTO Program Requirements

• The "Best Practice" for controlling hazardous energy is lockout in conjunction with tagout.
• Each energy isolation point should have a lock and a tag.
• Locks must be standardized and used only for LOTO.
• Multiple-location companies must have consistent locks/tags across all locations per OSHA.
• Tags must name the person who attached the lock and can optionally include a photo.
• If a tag isn't used, the employee's name must be on the lock.
• LOTO training is required for Authorized and Affected Employees when changes occur to machinery, procedures, or hazards.
• The frequency of training is not specified by OSHA.
• Training generally is classroom with hands-on review for Authorized employees, and stand-up or toolbox meetings for Affected employees.
• Employers must audit the LOTO program and procedures annually, as required by OSHA 1910.147(c)(6)(ii).
• OSHA requires employers to certify that LOTO procedures have been audited annually.
• The certification for LOTO procedures must include: the machine's name, the date of the inspection, the employee(s) involved in the audit, and the name of the auditor

OSHA Enforcement

• In 2017, there were 2,406 OSHA violations found.
• Common LOTO violations include lack of a LOTO program and procedures, lack of training, lack of an annual audit, and issues with LOTO procedure content.
• For the last 18 months, OSHA inspectors have focused on employee interviews as part of their inspection process.
• All employees on the production floor must be prepared to answer LOTO questions.
• Effective January 1, 2018, all LOTO procedures posted on each machine must contain pictures of the energy isolation points.
• Common violations include missing or incomplete procedures, missing employee names on locks/tags, insufficient training, lack of audits and/or certifications, improper lockout devices, keys left in locks, and a failure to verify zero energy state.
• Combination locks are not allowed because the combination could be shared
• A common mistake is when employee attaches his lock to the LOTO point but neglects to close it

LOTO Enforcement Examples

• BWAY (Chicago, IL): $503,000 for lack of procedures and annual LOTO audit
• Ashley Furniture (Wisconsin, Mississippi): $1.75M for multiple LOTO and machine guarding issues
• C.M. Trailers & Truck Beds (Kingston, OK): $535,000 for multiple LOTO and machine guarding issues

LOTO Program Steps

• Step 1: Know the types and magnitudes of energy. All energy sources must be listed on each machine's unique LOTO procedure.
• Step 2: Notify all "affected" and "other" employees of impending shutdown.
• Step 3: Use normal stopping procedures when shutting down equipment.
• Step 4: After shutdown, operate all energy isolation devices so the equipment is disconnected from energy sources.
• Step 5: Attach locks & devices to each isolation point, and tag should accompany each lock.
• Step 6: Ensure all potential or residual energy is controlled by blocking elevated parts block/release springs, relieve system pressure drain fluids vent gases ,allow system to cool and discharge capacitors.
• Step 7: Before any servicing begins, verify effectiveness of LOTO and the Zero Energy State and return controls to the "OFF" position after testing.
• Step 8: Complete required service work and avoid doing anything that could potentially reactivate the equipment, it's OK to interrupt LOTO, but must be reapplied.
• Step 9: All locks, tags, and devices must be removed by the person who applied them tools removed and guards replaced , verbally inform all affected employees release is complete.

Special Circumstances

• Group LOTO: Each employee applies their own lock/tag to each isolation point.
• Shift Changes: To perform a “LOTO Transfer” to another authorized employee if stepping away from the lock.
• Lock Removal Procedure: Supervisor must be notified if lock owner not present
• Contractors have no exception to LOTO procedure
• Master Key: The master key must be controlled at all times by a management official responsible for employee safety, and Cannot be copied.

LOTO Exceptions

• Electrical Troubleshooting Tasks: LOTO is not required if power is required when troubleshooting.
• Cord & plug connected equipment: When the plug is the only source of energy and is under continuous control.
• "Alternative Protective Measures": Protective measures besides LOTO, but alternative must be documented, communicated, and approved by the site Safety Manager prior to utilizing.

Summary

• Locate, isolate, and control every energy source associated with the machine, using a machine-specific LOTO procedure.
• Prioritize creating LOTO procedures (with pictures) for every piece of equipment ASAP.
• Designate locks and LOTO devices, ensure your name is on the lock and/or tag, and never share locks or keys.
• Follow the nine-step LOTO procedure and remember to verify the zero-energy state.
• Ensure protection during special situations like shift changes and lock removals.