1. OR-OSHA publishes "Oregon OSHA’s guide to controlling hazardous energy"
  2. ZERO energy state (ZES) means ZERO energy state
  3. LOTO Accident Data from OSHA's Preamble
  4. More LOTO Adventures
  5. MIOSHA Guidance: Minor Tool Changes and Adjustments, and Other Minor Servicing Activities
  6. LOTO and Contractors
  7. Lockout is the RULE, “minor servicing” is the exception
  8. It is Lockout OR tagout... NOT BOTH
  9. LOCKOUT/TAGOUT Methods and Sample Procedures (CAL-OSHA)
  10. Why does OSHA permit the LOTO exception ONLY on electrical cord and plug equipment?
  11. OSHA's requirement for "machine specific" LOTO procedures and the "exception"
  12. LOTO fatality while cleaning (NY FACE)
  13. From a recent OSHA citation for LOTO, yes we still have problems!
  14. LOTO Fatality - Caught in conveyor system (TN-OSHA II #28 - 2010)
  15. A traditional LOTO fatality - worker started equipment on another worker (TN-OSHA #23)
  16. Clearing up a couple of LOTO myths
  17. Palletizer kills temporary worker, 21, on his FIRST DAY of work (LOTO)
  18. OSHA takes issue with EVERY Authorized Employee having a key to the lockbox
  19. Have you ever seen/heard of this LOTO practice before?
  20. LOTO Periodic Inspections and their significance
  21. LOTO Program Suggestions from a reliable source!
  22. OSHA cites manufacturing plant for exposing workers to hazardous energy sources during machine servicing
  23. LOCK IT OUT!!! WARNING - Image may be upsetting to some
  24. Is tagging a blind flange or slip blind "tagout"?
  25. De-enerizing Stored Energies
  26. Verifying the content of lockout programs
  27. Supervision in Manufacturing - Guards & Lockout (Video)
  28. Defining Exclusive Control under LOTO activities
  29. Minor Servicing Alternative Safety Measures
  30. OSHA, LOTO and the unexpected movement of trucks
  31. Proper LOTO or a serious problem? (POLL)
  32. Verifying ZES is DIFFERENT for electrical workers!
  33. My TOP 12 Life Saving LOTO Principles
  34. Group LOTO Verification of ZES Requirements
  35. Periodic Inspections
  36. LOTO Training Requirements
  37. Shift or Personnel Changes
  38. Verification of ZERO ENERGY STATE (ZES)
  39. Tagout and Full Employee Protection (e.g. Tag Plus)
  40. Can ALL your LOTO Training needs be met by On-Line Training?
  41. LOTO on Chemical Process and Piping Systems
  42. Does your LOTO program contain "enforcement" procedures?
  43. GREAT LOTO Cartoon (VIDEO)
  44. Lock out. It takes just seconds to lose a limb (VIDEO)
  45. One of my favorite LOTO videos (VIDEO)
  46. FALSE Sense of Safety...using interlocks in Lieu of LOTO!!!
  47. We have THREE Choices to Identify our Lockout Locks
  48. Tagout vs. Lockout
  49. Company argues before the OSHRC that LOTO does not apply to their die changing activities - an analysis of a OSHRC 2009 decision
  50. Cord and Plug Equipment and "Line of Sight"
  51. Tagout vs. Lockout #2
  52. 911 Call - What REAL TRAGEDY sounds like (911 audio)
  53. Grouping equipment for purposes of conducting periodic LOTO inspections     
  54. LOTO Machine Specific Procedures

OSHA's Standard on the Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) contains the following paperwork requirements:

Paragraph (c)(4)

Employers must document the procedures used to isolate from its energy source, and render inoperative, any machine or equipment prior to servicing, maintenance, or repair by employees. These procedures are necessary if activation, start up, or release of stored energy from the energy source is possible, and such release could cause injury to the employees. The required documentation must clearly and specifically outline the scope, purpose, authorization, rules, and techniques employees are to use to control hazardous energy, and the means to enforce compliance, and include a number of elements specified by this paragraph.

The employer will use the information in this document as the basis for informing and training employees about the purpose and function of the energy-control procedures, and the safe application, use, and removal of energy controls. In addition, this information enables employers to effectively identify operations and processes in the workplace that require energy-control procedures.


Paragraph (c)(6)(ii)

The Standard requires employers to conduct inspections of energy-control procedures at least annually. An authorized employee (other than an authorized employee using the energy-control procedure that is the subject of the inspection) is to conduct the inspection and correct any deviations or inadequacies identified. For procedures involving either lockout or tagout, the inspection must include a review, between the inspector and each authorized employee, of that employee's responsibilities under the procedure; for procedures using tagout systems, the review is to assess the employee's knowledge of the training elements required for these systems. Under paragraph (c)(6)(ii), employees must certify the inspection by documenting the date of the inspection, and identifying the machine or equipment inspected and the employee who performed the inspection.

The inspection records provide employers with assurance that employees can safely and effectively service, maintain, and repair machines and equipment covered by the Standard. These records also provide the most efficient means for an OSHA compliance officer to determine that an employer is complying with the Standard, and that the machines and equipment are safe for servicing, maintenance, and repair.


Paragraph (c)(7)(iv)

Under this paragraph, employers must certify that employees completed the required training, and that this training is up-to-date; the certification is to contain each employee's name and the training date. The training program is to enable employees to understand the purpose and function of the energy-control procedures, and provides them with the knowledge and skills necessary for the safe application, use, and removal of energy controls. It specifies a number of elements that employers are to include in the training program for authorized and affected employees, and other employees who work, or may work, near operations using the energy-control procedure. If the employer uses a tagout system, the training program must inform employees of the limitations of tagging systems specified by the Standard. Employers must retrain authorized and affected employees if: A change occurs in their job assignments, the machines, equipment, or processes such that a new hazard is present; the employer revises the energy-control procedures; employers have reason to believe, or the periodic inspection required under paragraph (c)(6) indicates, that deviations and inadequacies exist in an employee's knowledge or use of energy-control procedures.

Training provides employees with the knowledge and skills necessary for implement safe application, use, and removal of energy controls, and enables them to prevent serious accidents by using appropriate control procedures in a safe manner to isolate these hazards. In addition, written certification of the training assures the employer that employees receive the training specified by the Standard, and that retraining occurs as necessary. These records also provide the most efficient means for an OSHA compliance officer to determine whether or not an employer performed the required training at the necessary and appropriate frequencies.


Paragraph (c)(9)

This provision requires the employer or authorized employee to notify affected employees prior to applying, and after removing, a lockout or tagout device from a machine or equipment. Such notification informs employees of the impending interruption of the normal production operation, and serves as a remainder of the restrictions imposed on them by the energy-control program. In addition, this requirement ensures that employees do not attempt to reactivate a machine or piece of equipment after an authorized employees isolated its energy source and rendered it inoperative. Notifying employees after removing an energy-control device alerts them that the machines and equipment are no longer safe for servicing, maintenance, and repair.
Paragraph (f)(2)

If an onsite employer uses an offsite employer (e.g., contractor) to perform the activities covered by the scope and application of the Standard, the two employers must inform each other regarding their respective lockout or tagout procedures. Onsite employers must ensure their employees understand and comply with the restrictions and prohibitions of the offsite employers' energy-control programs. This provision provides employees of onsite employers with information about the unique energy-control procedures used by an offsite employer; this information prevents any misunderstanding by either plant employees or outside service personnel regarding the use of lockout or tagout procedures in general, and the use of specific lockout or tagout devices selected or a particular application.

Screen Shot 2015 05 31 at 9.01.53 PMOnce again OR-OSHA has put out a high quality publication!  This one is on Lockout/Tagout (LOTO) and is a MUST have for every facility.  Yes I know, it only counts in Oregon, but this publication explains LOTO like none other and can be used by any workplace struggling with LOTO regardless of what state you are in.  This publication EXPLAINS the myths behind "minor servicing exception", "out of service" locks, etc.  Here is a one of their explanation...

We have all heard the stories about "pressure" killing workers.  One of my favorite trick questions to ask a group attending my LOTO training is "just how much pressure does it take to kill a human?"  The incident below occurred at a power generation station and involved 40 psi, but PLEASE keep in mind that much less energy can result in similar outcomes.  This is a great incident to include in your PRCS and Line Break training.

Screen Shot 2015 05 24 at 10.11.45 PM

Some interesting, yet very DATED data, regarding LOTO accidents.  This is from OSHA's preamble when they were trying to justify the need for the Control of Hazardous Energy Standard.  TABLE III - ACTIVITY OF TIME OF ACCIDENT and TABLE IV - CIRCUMSTANCES OF INJURIES are VERY TELLING and in my professional opinion, still reflect the LOTO accidents we see today.  So even though OSHA’s LOTO Standard came into effect in 1989, we are still seeing way too many injuries related to LOTO.

11136681 10206422918041714 1506093172319894291 nYou spend enough time working on Lockout/Tagout (LOTO) you are bound to come across some crazy situations.  Luckily I have some world class clients who not only allow me to share my "interesting finds" but encourage me to share with all of you.  This most recent find was at an OSHA VPP STAR site.  We have been hired to do  program specific audits each quarter, with an emphasis on energy control.  This means even though I may be auditing flammable liquids this quarter, I am ALWAYS auditing LOTO and conducting "periodic inspections" (and yes I am an "authorized employee" within their LOTO program - I wrote it, wrote 99% of the machine specific control plans, and still do all the LOTO training at the facility).  For the most part this facility KNOWS LOTO and LIVES IT DAILY; but we all have flaws - no one or no facility is perfect.  Hence why we need LAYERS of PROTECTION in all our safety efforts.  So today I was making my rounds talking with everyone and came across one of the safety committee members who was cleaning a piece of equipment.  He knew I was there to do an audit, as he had participated in many audits with me before.  He was PROUD and CONFIDENT of his ability to meet all LOTO requirements.  But, the good will ended there.  Here is the image of his electrical isolation - do you see anything wrong?

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