When Do OSHA Lockout/Tagout Rules Apply at My Site?

Posted on 3/7/2017 by Lee Ann Coniglione

A steam valve is automatically turned on burning workers who are repairing a downstream connection in the piping.

A jammed conveyor system suddenly releases, crushing a worker who is trying to clear the jam.

Internal wiring on a piece of factory equipment electrically shorts, shocking the worker who is repairing the equipment.

These three real-life workplace incidents illustrate the crucial responsibility employers have to protect employees under OSHA’s Lockout/Tagout standard at 29 CFR 1910.147. In each scenario above, you will notice that the work being performed took an unfortunate turn due to improper control of hazardous energy. While incidents like these are every safety manager’s worst nightmare, they are largely preventable through compliance with the Lockout/Tagout standard and effective employee training.

Each year, OSHA releases its Top 10 most frequently cited safety and health violations. OSHA’s Top 10 for fiscal year 2016 year, compiled from nearly 32,000 workplace inspections conducted by Federal OSHA employees, is available now. Coming in at number five on the list is lockout/tagout (LOTO), also called “Control of Hazardous Energy.”

The prevalence of machine-related hazards and the injuries they cause are a major concern for employers, and clearly there is work to be done to improve safety surrounding machine work, servicing, and maintenance. 

What Machines Are Covered by LOTO?

OSHA lockout tagout trainingControlling hazardous energy, in its many forms, is the purpose for OSHA’s Lockout/Tagout standard at 29 CFR 1910.147. Employers are responsible for recognizing and controlling all sources of hazardous energy in the workplace.

While many of us may first think of electrical sources when it comes to hazardous energy, numerous other forms of hazardous energy must also be considered. For instance, mechanical, hydraulic, pneumatic, chemical, and thermal energy sources all pose their own inherent risks to workers.

When these hazardous energy sources are not properly controlled, the outcome is often disastrous and life-altering. Failure to adequately control hazardous energy can lead to crushing injuries, burns, lacerations, amputations, fractures, and even death caused by electrocution.   
The good news is that such workplace incidents can be prevented. Prevention begins with each employer and his/her duty to develop and implement a robust lockout/tagout program. While LOTO programs will no doubt differ from place to place, the intent of each program remains the same: to protect employees from hazardous energy sources while performing service and/or maintenance work on equipment and machinery.
Does that mean every single piece of equipment and machinery in the workplace falls under the requirements of the standard? After all, that would account for most of the things we interact with and use on a daily basis in the workplace. The short answer to that question is no. However, it’s not quite as cut and dry as that.  

What Activities Are Covered Under LOTO?

OSHA Lockout tagout trainingLet’s talk about those activities covered under the LOTO standard. Here again, we see the phrase “servicing and maintenance,” which is a recurrent throughout the regulations. Essentially, most servicing- and maintenance-related work performed on equipment and machinery will be covered under the standard whenever there is the possibility that the equipment could unexpectedly start up or release stored energy. 

What does OSHA consider to be servicing and/or maintenance work? OSHA defines this term to mean workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment, and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy. [29 CFR 1910.147(b)]

While we barely scratched the surface when it comes OSHA’s lockout/tagout standard, hopefully, you’ve found the information useful for evaluating the applicability of the lockout/tagout regulations within your own workplace.

Source for three real-life incidents:

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Be confident your employees know what it takes to protect themselves and co-workers with effective lockout/tagout procedures. Only $29 per student, the new Lockout/Tagout Online Course guides employees through the application and removal of lockout/tagout devices. Workers who complete this course will have a stronger understanding of the hazards they face, and the requirements they must follow to prevent injuries and keep your site in compliance.  

Tags: 29, CFR, lockout tagout, osha, safety training, workplace safety

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