By Jim Wood
The Lockout/Tagout (LOTO) standard is nothing new and is something I have talked about in this column for years. By way of reminder, OSHA’s website (www.osha.gov) defines LOTO as “specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.”
Very little has changed with the standard since it was first published, but in the past couple of years there has been a lot of renewed interest in LOTO by OSHA. It is fast becoming OSHA’s number one money maker. At least one half-dozen cases have come to my attention with willful initial penalties ranging from 27 to 70 thousand dollars each.
These penalties were levied against companies that did have written programs and employee training. However, the programs were either not detailed enough or employees were not adequately trained according to OSHA inspectors, or the companies were not enforcing the programs. You can have excellent written programs and employee training, but if lockout procedures are not part of your daily maintenance and set-up routine you will be subject to heavy fines should OSHA inspect your facility.
Thousands of dollars in penalties are assessed each year for lockout/tagout violations on almost every citation issued. Some typical violations include:
• No written or an incomplete written program
• Lack of energy control procedures
• No sequence of lockout
• Lacking an outside contractor portion
• Lacking guidelines for multiple lock control
• Lacking guidelines for removing another person’s lock
• Lacking various lockout devices
• Lacking lock and key control procedures
• Lacking a hazard analysis and lockout procedures for each machine
• Lacking a lock identification procedure
• Inadequate employee training
• Failure to conduct periodic inspections of lockout situations
• Failure to conduct an annual review and certification
There are two frequently cited and least known portions of the lockout/tagout program. One is failure to document the lockout procedure on every machine or like types of machinery in your plant. This is part of the hazard analysis. You must recognize all forms of energy including: electrical, mechanical, hydraulic, gravity, water, thermal, chemical, pneumatic and springs under load. Forms of energy should be documented for each machine and either cataloged in the lockout program or better yet, each machine could be tagged with the various energy sources with instructions on how to lock out that particular machine.
The other frequently cited portion is the lack of a written periodic assessment of your program. At least two or three times each year, a member of management must inspect a known lockout situation in the plant and document their findings. In a situation where proper procedures were not followed, employees involved must be trained on the spot. Retain this inspection assessment as part of the written program.
All locks must be tagged with the employee’s name. Always lockout, never tagout, unless it can be proven that a tag can provide protection at least as effective as locks and would ensure “full employee protection.”
Jim’s Regulatory Tip:
Don’t Forget That The Program Covers Lockout During Set-Up On All Machinery
I recommend three levels of lockout training: 1) Informational training for the general work force, 2) Instructional training for those employees that are authorized to perform lockout, and 3) An additional level of training for those employees performing machine set-up. This training would be machine-, and in some cases, job-specific. I recommend publishing step-by-step machine set-up instructions for all machinery or like types of machinery in the plant. Post these instructions on each machine. These instructions should advise the employee when and how to lockout the machine they are working on during set-up. Each set-up employee must be individually trained in these procedures. As you know, there are times during set-up that the machine must be under power and the employee must be trained in safe procedures during these periods. There are also times during set-up that the machine must be locked out. 
