Manufacturing Lockout/Tagout Procedures for Employers

Understanding Lockout/Tagout Requirements

The Control of Hazardous Energy standard, commonly known as Lockout/Tagout (LOTO), is found at 29 CFR 1910.147. This standard requires manufacturing and general industry employers to establish procedures for isolating energy sources on machines and equipment during servicing and maintenance. LOTO consistently appears among OSHA's most frequently cited standards, reflecting its critical importance and the frequency of violations.

Hazardous energy sources include electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and gravitational energy. Any employee performing servicing or maintenance where the unexpected energization, startup, or release of stored energy could cause injury must be protected by LOTO procedures.

Developing Written Procedures

Employers must develop machine-specific LOTO procedures for each piece of equipment that requires servicing. Each procedure must identify the type and magnitude of energy the machine uses, the specific energy control methods to be employed, and the steps for shutting down, isolating, blocking, and securing the machine.

Procedures must also include steps for verifying that the equipment has been properly de-energized before servicing begins. A generic or one-size-fits-all procedure is inadequate and will not withstand OSHA scrutiny. The only exception is when a machine has a single energy source that can be readily identified and isolated.

Training Requirements

OSHA requires three levels of LOTO training based on employee roles. Authorized employees are those who perform the lockout and must receive training on recognizing applicable hazardous energy sources, the type and magnitude of energy in the workplace, and the methods and means necessary for energy isolation and control.

Affected employees are those whose job requires them to operate or use machines on which servicing is performed under LOTO. They must be trained on the purpose and use of energy control procedures. Other employees whose work operations are or may be in areas where energy control procedures are used must be instructed about the prohibition against attempting to restart or reenergize equipment that is locked or tagged out.

Periodic Inspections

Employers must conduct periodic inspections of their LOTO procedures at least annually. The inspection must be performed by an authorized employee other than the one utilizing the procedure being inspected. The inspection must include a review between the inspector and each authorized employee of the employee's responsibilities under the procedure.

For lockout procedures, the periodic inspection must include a review of employee responsibilities. For tagout procedures, the inspection must also include a review with both authorized and affected employees of their responsibilities and any limitations of tagout devices.

Common Violations and Best Practices

Frequent LOTO violations include failure to develop machine-specific procedures, inadequate training documentation, failure to conduct annual inspections, and allowing employees to use only tags without locks when lockout is feasible. Employers should maintain a master list of all equipment requiring LOTO procedures, ensure adequate supplies of locks and tags, and integrate LOTO compliance into their overall safety management system.