Audit, Compliance and Risk Blog

Most Occupational safety and Health Administration (OSHA) electrical safety and machine guarding standards apply to protect employees from electrical and kinetic energy hazards during routine operations. But OSHA also requires protection during equipment servicing and maintenance, lest employees be injured by “unexpected” equipment energization, start up, or release of stored energy. OSHA’s Control of Hazardous Energy Standard—more often called the Lockout/Tagout or “LOTO” Standard after its primary compliance requirements—requires employers to establish and implement safety procedures to control such hazardous energy.

Which Types of Hazardous Energy Might Equipment Store When Off?

OSHA requires energy control procedures during servicing and/or maintenance of machines and equipment that may expose employees to injury from unexpected startup or the release of stored energy. Stored energy may include any of the following:

• Electrical 

• Mechanical

• Hydraulic

• Pneumatic

• Chemical

• Thermal

• Other energy sources.

If there are no such machines or equipment in a workplace, LOTO doesn’t apply. In addition, OSHA excludes the following activities from energy control requirements:

• Work on cord-and-plug connected electric equipment while unplugged from its electrical source, if the employee performing the maintenance has exclusive control of the plug.

• Hot tap operations with transmission and distribution systems for gas, steam, water, petroleum, or similar products when performed on pressurized pipelines, if the employer demonstrates that:

• Continuous service must be maintained.
• System shutdown is impractical.
• Employees use documented procedures and special equipment to protect themselves.

Which Lockout and Tagout Devices Can Be Used?

OSHA allows physical lockout of hazards (sometimes referred to as “blockout”), and may allow “tagout” instead.

A lockout device is an energy control device that can be locked out by use of a positive means such as a key or combination lock to hold an energy switch (in the regulations, an “energy isolating device”) in the safe position. This prevents unauthorized personnel from turning on a machine or equipment while it is being serviced.

A tagout device is a prominent warning—such as a tag or sign—securely fastened to an energy switch following an established procedure. The tag indicates that no one is to turn on the energy switch and the equipment until the tagout device is removed, but does not physically prevent someone from doing so.

Which Employees Are Covered By the LOTO Standard – And How?

The LOTO Standard identifies several categories of employees:

• Affected employees operate equipment that requires servicing or maintenance during lockout or tagout, or work in an area in which such servicing or maintenance is being performed.

• Authorized employees lock out or tag out machines or equipment in order to perform servicing or maintenance on that machine or equipment.

• Other employees are neither authorized nor affected but may be present.

Does the Workplace Have an Energy Control Program?

OSHA requires employers to develop and implement a program to ensure that machines and equipment are isolated from their energy sources and made inoperative before any employee performs any servicing or maintenance where the unexpected energizing, startup, or release of stored energy could cause injury. This program must include energy control procedures, employee training, and periodic inspections.

Energy control procedures must clearly specify the scope, purpose, authorization, rules, and techniques to control hazardous energy, and the employer’s means of enforcing compliance. These must include:

• Preparation for shutdown.

• Machine or equipment shutdown.

• Machine or equipment isolation (by an authorized employee).

• Lockout or tagout device application (by an authorized employee).

• Release of stored energy (by an authorized employee) after applying lockout or tagout devices.

• Verification of isolation before starting work on locked out or tagged out equipment.

OSHA generally requires employers to document these procedures. However, no documentation is required for a particular machine or equipment if all the following points apply:

• No dangerous levels of stored or residual energy remain after shut down.

• It has a single energy source that can be readily identified and isolated.

• It is completely de-energized and deactivated by isolating and locking out the energy source.

• It is isolated from its energy source and locked out during servicing or maintenance.

• One device is enough to accomplish lockout.

• The lockout device is under the exclusive control of an authorized employee performing the servicing or maintenance.

• The servicing or maintenance does not create hazards for other employees.

• No accidents have involved unexpected activation or re-energization of the machine or equipment during servicing or maintenance.

Training must be provided to employees, to ensure that they understand the purpose and function of the energy control program. Employees must acquire the knowledge and skills they need for safe application, usage, and removal of the energy controls, and must demonstrate proficiency at their tasks. Training includes initial training for affected and authorized employees, and retraining if equipment, procedures or job assignments change. The employer must certify that training has been completed, and that the training program is kept up to date.

Workplace inspections of the program elements and each device must also be conducted at least annually. Inspections must meet the following criteria:

• Be performed by an authorized employee, designated as the “inspector,” who is not using the specific energy control procedure being inspected.

• Be used to correct any deviations or inadequacies identified.

• For lockouts: include a review, between the inspector and each authorized employee, of that employee’s responsibilities under the energy control procedure.

• For tagouts: include a review, between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure.

The employer must certify that appropriate inspections have been completed.

How Must Employers Coordinate With Other Employers With Workers At A Site?

Whenever outside servicing personnel are active in energy control-related activities the onsite employer and the outside employer must inform each other of their respective lockout or tagout procedures. Both employers must ensure that their employees understand and comply with the restrictions and prohibitions of the other employer’s energy control program.

Self-assessment Checklist

Does the employer meet applicable LOTO Standard requirements:

• Has the employer identified machines and equipment in the workplace that contain electrical, thermal or other energy in operation?

• If so, has the employer evaluated which machines or equipment may retain potentially hazardous energy even when not in use?
• If so, what types of energy are present in each such machine or equipment?

• Has the employer identified lockout devices that can protect employees against energy hazards when equipment is being services or maintained?

• Has the employer identified tagouts that can protect employees against energy hazards when equipment is being services or maintained, by alerting them to the hazards?

• Has the employer implemented an Energy Control Program?

• If so, does it identify affected employees?
• If so, does it designate authorized employees?
• Does it include all required energy control procedures?
• Does it include required training?
• Does it include required inspections?
• Are procedures and compliance activities documented, including certifications?

Where Can I Go For More Information?

• OSHA’s Control of Hazardous Energy (Lockout/Tagout) webpage 

• OSHA’s online Lockout-Tagout Interactive Training Program (“eTool”) 

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