Are You Locking and Tagging Like You Should?

Proper lockout tagout (LOTO) is absolutely necessary to protect employees.  Without total isolation of hazardous energy, a serious injury may occur.  It is not a question of if, but when this may happen.  A good way to ensure total energy isolation is to envision the piece of equipment to be isolated as being in a box.  Every energy source coming into that box must be isolated.  This usually requires the interaction of multiple disciplines, including maintenance, engineering, operations, and safety.  These disciplines must work together to ensure ALL hazardous energy sources have been identified, and then determine how to isolate these sources.

Once all hazardous energy sources and the means to isolate them have been identified, documentation is required to ensure that all the energy sources are isolated every time.  This requires a procedure.  OSHA requires equipment-specific LOTO procedures for all equipment that has more than a single isolation source¹.  These procedures must have the following information included:

1. A specific statement of the intended use of the procedure
2. Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy
3. Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them
4. Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures²

Although not required in the procedure, photographs of the isolation devices (valves, breakers, disconnects, etc.) make the procedures more user friendly and increases the likelihood that the identified lockout points will be isolated.  Also helpful are pictures of the devices to be used to lockout the energy sources. There is no required template for the procedure but consistency is key. Make sure you have a good template to document your procedures and aid in training.

Circuit Breaker Lockout Device                     Wheel valve Lockout Device

If you have questions or would like assistance with your LOTO program or equipment-specific LOTO procedures, please contact us at cmi@complianceplace.com.

¹29 CFR 1910.147(c)(4)(i)

²29 CFR 1910.147(c)(4)(ii)

Written by Peter Schlenker, Associate Health and Safety Specialist