Lockout/Tagout Compliance: What Every Employer Needs to Know
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Lockout/Tagout Compliance: What Every Employer Needs to Know

04/25/19

Occupational Safety and Health Administration (OSHA) rules require an employer to use strict lockout/tagout procedures wherever the accidental release of energy could injure workers. That injury may come from electric shock, the sudden activation of equipment during maintenance or other means. But how important is it to comply with the related standards, really? 

The following statistics suggest an answer: 

  • In 2018, two of the construction industry’s leading causes of worker fatality were electrocutions and “caught-in/between” injuries. Perfect compliance with lockout/tagout procedures could prevent many, if not most, of these accidents.
  • The same year, the safety standard that describes lockout/tagout procedures for general industry was among OSHA’s top 10 most-cited violations. 
  • Violations of this standard were the fifth most common source of OSHA citations in 2018. For context, rules about ladders in the construction industry were number six on the list of most-cited OSHA violations; instructions on respiratory protection came in fourth.  

Clearly, locking or tagging equipment is vitally important to maintaining a safe workplace. Just as plainly, compliance could improve across the board — and better compliance starts with better procedures. Here are five crucial elements of a successful lockout/tagout program: 

  1. Consult the OSHA Standards on Lockout/Tagout Programs in Your Industry

    This one should be easy enough. Just check out the OSHA standard about lockout/tagout compliance, right? Unfortunately, it’s a bit more complicated than that. 

    At least 10 different OSHA standards cover control of hazardous energy through lockout/tagout procedures. The good news is that most employers only need to focus on two of them: 29 CFR 1910.147, “The control of hazardous energy (lockout/tagout),” requires lockout/tagout procedures on powered equipment in most industries; and 29 CFR 1910.333, “Selection and use of work practices” involving electrical systems, covers lockout/tagout procedures designed to prevent electrical shock.  

    Employers in the construction industry should consult OSHA standards 1926.417 and 1926.702. The former requires tagging of all circuits or energy-control points on electrical equipment. The latter makes a similar rule for concrete and masonry equipment. Finally, OSHA standard 1926.64 details lockout/tagout procedures surrounding hazardous chemicals at construction sites. 

  2. Know When to Lock Out Equipment and When Tags are Acceptable

    It may be called a lockout/tagout program, but locks and tags are not equal. Wherever possible, it’s better to lock equipment in an energy-isolated state between uses. The lock prevents devices from being energized, regardless of user error. Only the user with the key to the locking device can restore power to the equipment.  

    Tagout programs are required to provide an equal level of protection to lockouts. A tag warning users of the hazards is only half of the equation; you must also prevent accidental energizing by removing a circuit, detaching a valve handle, activating a block on a control switch or some similar method.  

    Either way, OSHA prefers the use of locks over tags, even with supplemental safety precautions accompanying tagout devices. In a 2002 publication on energy control, the agency stated that “OSHA considers lockout devices to be more secure and more effective than tagout devices in protecting employees from hazardous energy.”

    Worker placing safety tag

  3. Cover all Three of the Core Components of an Energy Control Program

    In order to comply with OSHA standards, a lockout/tagout program must include at least three major elements: procedures that detail what gets locked or tagged, by whom and how; ongoing training on those procedures; and periodic inspection to ensure that the procedures are still adequate to protect workers. 

    A complete energy control program will provide all necessary details on all three subjects, complete with accompanying documentation — which brings us to our next point. 

  4. Ensure Proper Documentation of the Energy Control Program

    OSHA standard 1910.147(c)(4)(i) specifies that, not only must employers develop and ensure the use of lockout/tagout procedures, they must document these procedures in writing. 

    There are exceptions — for instance, when the employee who performs maintenance is the only one with access to the lockout device, or when equipment only has one clear, easy-to-use power source — but where there’s potentially hazardous energy in the workplace, OSHA requires a written plan to keep that energy from injuring workers. 

  5. When in Doubt, Remember the Fundamental Goal of Lockout/Tagout Procedures

    When you’re rewriting lockout/tagout procedures, it’s easy to get lost in the details. Clear things up by keeping a single guiding principle in mind. Here’s how standard 1910.147 describes the purpose of the rule: 

    “This section requires employers to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up, or release of stored energy in order to prevent injury to employees.” 

    This last point — preventing injury to employees — applies equally to energy-control standards for electrical systems, in the construction industry and to every word of OSHA’s Occupational Safety and Health Standards. 

    When in doubt, ask yourself if a proposed rule will help to prevent injury. If it will, it belongs on the books. Remember that OSHA doesn’t dictate how employers develop their own energy control programs; they just insist that these programs meet the requirements set forth in their standards.

Safety Tags
Note, also, that the primary OSHA standard on energy control considers all forms of energy that might lead to injury. The standard lists the major ones — electrical, chemical, thermal, hydraulic and mechanical energies — but also mentions that this list is not exhaustive. 

Essentially, if the sudden reenergizing of a machine could injure an employee, that piece of equipment should be included in the overall lockout/tagout procedure. With these procedures in place, and with continuous investment in training to ensure that every employee follows the rules, all employers can reduce the risk of injury — or worse — in the workplace. 

For more information on building an energy control program at your facility, see OSHA’s Lockout/Tagout Tutorial, available here