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LOTO: An OSHA Perspective

January 6, 2009

OSHA’s new lockout/tagout (LOTO) directive tells you how the agency is interpreting the LOTO standards – and how its inspectors will be enforcing it.

LOTO (Lock Out/Tag Out) is designed to protect workers performing service or maintenance on machinery and equipment from injuries resulting from the unexpected energization or startup of the equipment, or the release of stored energy in the equipment.

The LOTO standard requires facilities to adopt and implement practices and procedures to shut down the equipment, isolate it from its energy source(s), and prevent the release of potentially hazardous energy while maintenance and servicing activities are being performed.

The standard contains minimum performance requirements, and definitive criteria for establishing an effective program for the control of hazardous energy. However, it gives you, the employer, the flexibility to develop lockout/tagout programs suitable for your specific facilities.

The new compliance directive is the result of a “look-back” review of the LOTO standard, and it cancels and supersedes the old instruction, issued in September of 1990. Significant modifications in the new instruction include:

  • Changes in the instruction format necessitated by the OSHA Directive System (ADM 03-00-003)
  • Addition of Compliance Officer Safety guidelines
  • Inclusion of Citation Examples and additional guidance regarding Affirmative Defenses
  • Incorporation of compliance assistance flowcharts
  • Inclusion of additional guidance on the minor servicing exception, specific energy control procedures, periodic inspections, and unexpected energization
  • Inclusion of additional information and guidance on Alternative Methods to Lockout/Tagout (LOTO)
  • Inclusion of general reference material pertinent to hazardous energy control, including governmental, industrial, and national consensus standards, and
  • Addition of vehicle repair and maintenance standards and practices, including relevant Internet links, to assist employers engaged in activities.

Some other changes include:

  • Expanded explanations of some terms. For example, for “exclusive control,” the instruction now states “Under the exclusive control of the employee means that the authorized employee has the authority to, and is continuously in a position to, prevent (exclude) other individuals from re-energizing the machine or equipment during his servicing or maintenance activity.”
  • Inclusion of some material from OSHA’s online LOTO tutorial as examples of when and how LOTO should be conducted
  • More information about how LOTO and machine guarding work together

Perhaps most important, according to the revised manual, evaluation of LOTO compliance will now be part of ALL programmed inspections.

OSHA makes clear that the new directive is not a standard, regulation, or any other type of rule, and that nothing in it should be construed as requiring you to adopt any new practices, means, methods, operations, or processes beyond those already required by the agency and existing standards and regulations.

Still, savvy safety professionals will realize that, with its insights into how OSHA is interpreting the LOTO standard – and how OSHA inspectors will be enforcing it – the new directive is an essential bit of added intelligence on what to expect from the agency.

Also, with this new expanded focus on LOTO, it’s more important than ever to make sure your workers are properly trained on your organization’s LOTO procedures.

And if you need more reasons to do it, according to experts in the field:

  • Approximately 3 million workers who service equipment face a great risk of injury if lockout/tagout is not properly implemented.
  • Compliance with the LOTO standard prevents an estimated 120 fatalities and 50,000 injuries each year.
  • In 2007, LOTO was the third most commonly violated OSHA general industry standard, resulting in fines in excess of $7 million.
  • Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation.
  • In a study conducted by the United Auto Workers, 20 percent of fatalities (83 of 414) that occurred among their members between 1973 and 1995 were attributed to inadequate hazardous energy control measures, specifically, lockout/tagout procedures.

Elements of a Proper LOTO Program

Writing on the Centers for Disease Control and Prevention (CDC) website, Donald G. Bennett and Erik Forsen note that an effective lockout/tagout program should include the following elements:

  • An inspection of equipment by a trained individual thoroughly familiar with the equipment operation and associated hazards
  • Identification and labeling of lockout devices
  • Purchase of locks, tags, and blocks
  • A standard written operating procedure that is followed by all employees

Their recipe, however, begs the question of how to deal with the human element. In other words, how do you train your workers on LOTO, and once trained, how do you get them to follow the procedures you’ve taught?

CFSA offers an online training solution to provide the basic understanding of LOTO to your employees. This one-hour, self-paced course is designed to inform employees about the requirements for lockout/tagout during servicing and maintenance of machines or equipment. Also covered are the requirements of the OSHA Lockout/Tagout Standard, procedures for the application of locks and tags, and a discussion of the types of energy these procedures are designed to control. Click here to register now!

-Ed Sterrett
Central Florida Safety Academy

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