The countdown continues in the VelocityEHS Blog series on OSHA’s Top 10 Most Frequently Cited Standards for 2023! We’re down to #6 on the list with the Control of Hazardous Energy Standard, better known as Lockout/Tagout or LOTO.
Employees servicing or maintaining machines or equipment are at risk of life altering injuries or death if proper procedures aren’t in place to prevent hazardous energy from being released. This standard is about expecting the unexpected and making sure safeguards and controls are in place to ensure those working on or with machines or equipment are not at risk of potentially fatal injuries such as electrocution, burns, crushing, fractures, amputation, and others.
Simply put, the purpose of OSHA’s LOTO Standard is to prevent injury to workers servicing and/or maintaining equipment due to the unexpected energization, startup, or release of stored energy in machines and equipment.
The LOTO Standard specifically addresses hazardous energy sources such as:
- Electrical
- Mechanical
- Hydraulic
- Pneumatic
- Chemical
- Thermal
- Other energy sources
OSHA’s Control of Hazardous Energy (1910.147) Overview
The OSHA LOTO Standard requires employers to have an established energy control program. This consists of having documented energy control procedures, employee trainings, and periodic inspections. The purpose of the LOTO program is to ensure that before service and maintenance is performed, machines and equipment that could unexpectedly startup, become energized, or release stored energy are isolated from energy source(s) and rendered safe. This is generally done by de-energizing machines and equipment and then using the appropriate lockout and/or tagout devices to prevent accidental release of energy.
A lockout device physically prevents the operation of a machine or equipment by securing energy isolation points and preventing startup. A tagout device is a warning tag attached to energy isolation points indicating that employees should not operate the machine or equipment. The employer must follow a formal process before any employee removes these devices.
Employers must have rigid practices and procedures in place to ensure these energy sources are “isolated and rendered inoperative” before work is started, and that those procedures are followed by all employees working with this equipment.
LOTO Requirements
There are many different requirements, clearly outlined, within OSHA’s LOTO Standard. Starting with documented energy control procedures, employers must develop, document, and use specific procedures to control potentially hazardous energy when employees are servicing equipment or machinery.
The specific elements that the employer’s LOTO procedures must include, as required by OSHA, are a summarization of the scope, purpose, authorization, rules and techniques that the employer will use to control hazardous energy and the means to be used to enforce compliance.
At a minimum, the procedures must include:
- A specific statement of the intended use of the procedure
- Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy
- Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices, and a description of who has responsibility for them
- Specific requirements for testing a machine or piece of equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures
A LOTO training program is another key component. Employers are required to train each employee working on the equipment to ensure that they know, understand, and can follow the applicable provisions of the hazardous energy control procedures.
The training must cover at least three areas:
- The employer’s energy control (LOTO) program
- Energy control procedures specific to the employee’s work duties or assignment
- Other requirements of the OSHA standards related to LOTO
A third component of a LOTO program is periodic inspections. OSHA has a minimum requirement for annual periodic inspections to ensure procedures and policies are effective and being followed. The periodic inspections must have at least these components:
- An inspection of each energy control procedure
- A review of each employee’s responsibilities under the energy control procedure being inspected
However, the LOTO program should be reviewed and updated as often as necessary to account for installation of new equipment or control devices, new operators, or any other factors that could introduce potential exposures to hazardous energy sources.
What Are the Top LOTO Citations
There are many individual provisions within OSHA’s LOTO Standard and in 2023, there were 2,139 citations issued by OSHA. Among these provisions, the top five violation types were:
- 1910.147(c)(4)—”Energy control procedure.” 730 violations
- 1910.147(c)(7)—”Training and communication.” 491 violations
- 1910.147(c)(6)—”Periodic inspection.” 362 violations
- 1910.147(c)(1)—Energy control program: “The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.” 265 violations
- 1910.147(c)(5)—Application of control: “The established procedures for the application of energy control (the lockout or tagout procedures) shall cover the following elements and actions and shall be done in the following sequence.” 231 violations
It’s interesting to note that the top four of the five most commonly cited provisions of the LOTO Standard all relate to the LOTO program requirements we listed above, suggesting that many violations are rooted in the failure to establish and maintain a well-documented LOTO program.
What Are the Costs of LOTO Violations
According to OSHA, compliance with the LOTO Standard prevents an estimated 120 fatalities and 50,000 injuries each year. Unfortunately, in 2022 there were around 30 fatalities involving LOTO program failures reported to OSHA. Plus, employees that are injured from exposure to hazardous energy lose an average of 24 workdays for recuperation.
One fatal incident that took place at a compost manufacturing facility in Washington state in 2020 truly demonstrates the importance of the LOTO Standard. On the morning of the incident, a lead operator and his assistant were operating a biomass screening system which uses a stacker conveyor to deposit finished compost into stockpiles. When the assistant noticed that plastic debris was escaping from a waste container near the stacker, he went to get a leaf blower to clean up the debris, and returned to find that the stacker was shut down.
When he investigated what caused the stacker to stop operating, he saw the lead operator stuck inside the machine. The operator had tried to manually clear debris without first shutting the machine down, and the hood of his jacket got caught in the rollers, pulling him into the stacker. Employees freed the lead operator from the machine, but he died after nine days on life support. Subsequent investigations found that the company lacked a specific LOTO procedure for the stacker, which would have certainly reduced the likelihood of identifying and controlling specific risks associated with the equipment.
One fatality is one too many, which is why it is vital to understand and comply with OSHA’s LOTO Standard. Compliance means having a detailed, well-documented equipment-specific LOTO procedure in place that identifies what equipment is being isolated, when its being isolated, where the equipment is located, why this equipment is being isolated, who is performing the isolation, who will be approving the isolation—and have that LOTO procedure linked to a permit-to-work process to ensure the employee performing the isolation has been trained and qualified on safe LOTO procedures.
LOTO Resources
OSHA’s LOTO Standard might seem straightforward, but as you can see from the story above, there are simple steps that can easily be missed. Thankfully, OSHA has developed numerous tools and resources to help you safeguard employees from hazardous energy releases.
OSHA also has a LOTO eTool interactive training program that summarizes the key components of the standard in a question-and-answer format. It’s intended as a guide for understanding aspects of the LOTO Standard but is not a substitute for LOTO training program compliance.
Using Software to Help with Compliance—VelocityEHS Can Help!
LOTO is about planning and having appropriate and effective controls in place. Software can help you better manage these controls by allowing for better visibility and transparency across your organization. The VelocityEHS Control of Work Solution is designed by our EHS experts for EHS professionals like you, and provides a wide range of capabilities including Electronic Permit-to-Work, Contractor Management, Induction & Orientation, Qualification Management, and the NEW Lockout/Tagout capability coming soon.
Control of work is just one aspect of cultivating a safe work environment. The VelocityEHS Accelerate® Platform includes a wide range of innovative software solutions and built-in expertise to meet your toughest EHS and ESG challenges. Talk to one of our experts and discover how software can help make it easier for you to manage, maintain, and ensure long-term success.