Common employer mistakes in Lockout/Tagout programs

OSHA’s lockout/tagout (LOTO) standard includes the minimum requirements for controlling hazardous energy during the servicing and maintenance of machines and equipment. While LOTO is typically among OSHA’s top ten violations, the category jumped from 8th place in 2013 to 6th place in 2014 and had the second highest number of willful violations. A willful violation is issued when an employer disregards OSHA standards with full knowledge or if an employer is aware of a problem and does nothing to fix it. An example of a willful violation is if a piece of equipment does not have a LOTO procedure written for it. The minimum fine for a willful violation is $5,000 and it can be as much as $70,000, if no deaths resulted from the violation. If an employee dies as a result of the violation, criminal charges as well as a fine of $250,000 – $500,000 can be issued.

While the standard has been on the books for over 25 years, the same mistakes continue to be made. Here are some of the most common mistakes:

  1. No energy control program In 2014, the most-violated section of this standard involved establishing energy-control procedures. When companies have many types of equipment, documenting procedures can be very time consuming. Yet failure to have a comprehensive program puts workers at risk and violates OSHA standards.

    In addition to a summary program that addresses energy control procedures, employee training and periodic inspections, the program must include written equipment-specific LOTO procedures. The written procedure must specify steps for:

    • Shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy
    • The placement, removal, and transfer of lockout or tagout devices, and the responsibility for them

    In an effort to save time, some employers group equipment that is similar, but this can lead to problems. Machine-specific procedures should be documented for each unique piece of equipment, as it will have different energy isolation points, which must be identified in the procedure. Power sources must be clearly marked so workers can confidently lock out the machine they will be working on. Workers may lock out the wrong power source if markings are missing, incorrect, unclear, or worn. Providing procedures at the point of use and adding visuals to the step-by-step instructions are best practices.

    Another common mistake is to overlook facility support and operational equipment such as HVAC machinery, boilers, and compressors.

    OSHA provides a helpful LOTO Tutorial on its website.

  2. Failure to properly train employees The second most violated section of the standard was application of control, when authorized employees must perform certain procedures, in a specific order. Authorized employees (those who do the locking out in order to perform servicing or maintenance on the machine or equipment) must receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.

    A situation that is sometimes overlooked is shift changes. If servicing lasts more than one shift, LOTO protection cannot be interrupted. Leaving authorized employees remove their lock and the incoming employees place theirs on the isolating device. If the first employee leaves before the replacement’s arrival, a supervisor may place the lock on to ensure safety. Additionally, the incoming authorized employee must verify that all energy sources are locked out before beginning work.

    Other employees are divided into two categories: Affected employees (those whose jobs require them to operate or use a machine or equipment under lockout) must be instructed in the purpose and use of the energy control procedure. All other employees (those whose work operations are or may be in an area where energy control procedures may be used) must be instructed about the procedure and about the prohibition relating to attempts to restart or reenergize machines or equipment that are locked or tagged out.

    It’s important to properly document the training with records that show the name of the employee, the training date(s) and the name of the trainer. Retraining must be provided for all authorized and affected employees whenever there is a change in their job assignments, in machines, equipment, or processes that present a new hazard, or in the energy control procedures.

  3. Failure to properly Test/Position Machines/Equipment/Components This is the third most frequently cited section of the standard and requires that the following steps be taken:
    • Clear the machine or equipment of tools and materials
    • Remove employees from the machine or equipment area
    • Notify affected employees that the lockout devices are going to be removed
    • Authorized employees who applied a safety lock remove their own safety lock
    • Notify affected employees that the safety locks have been removed and that the machine or equipment is going to be energized
    • Energize and test the equipment
    • De-energize all systems and reapply energy control measures in accordance with established procedures
  4. Failure to train temporary, contract, or seasonal workers OSHA has put increased emphasis on protecting temporary workers and looks at the host company and the staffing agency as joint employers, making them both responsible. Depending on contractual language, staffing agencies may choose to do the general compliance training. However, the host company is required to provide hazard-specific training in a language and method that is understood by the workers when they are exposed to certain hazards, such as LOTO or Confined Space.

The citations by OSHA in 2014 included a number of tragic events that led to the death of an employee. A 35-year-old employee died when he became entangled in a rotary turbine engine while cleaning jammed clams from a shucking machine, a laborer was killed when a foreman activated the hydraulic controls to the rear door of the tank, and a 21 year-old temporary employer was crushed to death on his first day on the job by a palletizer machine.

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