The OSHA Control of Hazardous Energy standard, commonly known as lockout/tagout (LOTO), refers to 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. Approximately three million workers service equipment and face the risk of injury if LOTO is not properly implemented. According to OSHA, compliance with the LOTO standard prevents an estimated 120 fatalities and 50,000 injuries each year.
In 2017, OSHA issued over 3,000 citations under the LOTO standard. Some areas of the LOTO standard are cited more frequently than others. Here’s a closer look at common violations with “how-tos” to help you avoid citation and penalty and prevent serious injury:
Under [1910.147(c)(1)] of the LOTO standard, employers must have an energy control program that includes procedures, training and periodic inspections to prevent injury from the release of hazardous energy, including unexpected energizing or start up. This part of the standard requires a machine or equipment where the unexpected energizing, startup, or release of stored energy could occur and cause injury a to be isolated from the energy source and rendered inoperative.
How to ensure compliance: Develop a written LOTO program that includes procedures to protect employees from the potentially dangerous effects of hazardous energy. Some of the dangers of hazardous energy include accidental startups, electric shock and disabling injuries and death. These accidents are usually the result of someone taking a shortcut when servicing a piece of machinery. They occur when a worker doesn’t understand the equipment or maintenance procedures. A LOTO program lays the groundwork for preventing these types of accidents.
[1910.147(c)(4)(i)] of the LOTO standard requires employers to develop and document proper LOTO procedures, and put those procedures into practice. Section ii goes on to state the procedure must “clearly and specifically” outline the scope and purpose, authorization, rules, and techniques that should be used for controlling hazardous energy. The procedure must also include how compliance will be enforced.
How to ensure compliance: You must develop a LOTO procedure that covers the following:
Exception: You do not need to document the required procedure for a particular machine or piece of equipment when all of the following elements exist:
Training is essential. [1910.147(c)(7)(i)] of the LOTO standard requires employers to provide training to make sure employees understand the purpose and function of the energy control program, and to provide the knowledge and skills required for the safe application, usage, and removal of energy controls.” Training must extend to all employees who may have an impact on LOTO, including:
How to ensure compliance: You must identify and differentiate between authorized and affected employees, and other employees, and train accordingly.
Section [1910.147(c)(6)(i)] of the LOTO standard requires employers to conduct periodic inspections of the energy control procedure, annually at minimum, to ensure LOTO procedures and the requirements are being followed.
How to ensure compliance: An authorized employee, other than one who is doing the energy control procedure being inspected, must complete an audit, and each audit must be documented. The periodic inspections must contain at least two components:
Each energy control procedure must be inspected at least annually to ensure that the energy control program is being properly implemented. The inspector must be able to determine whether the inspected procedures are adequate, understood and followed by employees.
To learn more, register for our complimentary “Understanding OSHA compliance” webinar on November 1. For questions about LOTO or other OSHA requirements, please contact us.
If you could give human form to your safety culture, what would it look like?
Maybe it would be a thick-set, shirtless brute named Trog with a foul disposition beating out a drum cadence to keep your employees rowing in-sync.
Or would it be more like a fussy and constantly disapproving Dickensian paper-pusher named Fizzlewhite who has never met a rule or procedure he didn’t like, even though he hasn’t done most of the things he creates rules to address?
If you were to search the various “mommy blogs” and parenting advice websites out there, how many of them do you think would endorse the following practice?
A child’s safety should always be a top priority for any parent. When leaving children under the age of 10 alone in the house for lengthy periods of time, be sure to provide the kids with a loaded pistol with the safety off in case a stranger should happen by. In a pinch, recently sharpened knives can be substituted for the pistol.
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