Top 5 Violations of the Lockout/Tagout Standard and How to Avoid Them

Having an energy control program is the first step in preventing hazardous energy incidents.

Expecting the unexpected is never more important than when dealing with equipment that can release hazardous energy. Accidents involving hazardous energy can be life-changing, or even life-ending.

Yet the OSHA standard designed to prevent these accidents, The Control of Hazardous Energy (Lockout/Tagout), 29 CFR 1910.147, was the fifth most commonly violated standard in 2018, with 2,923 violations across all industries in 2018, according to an OSHA spokesperson.

Here are the top five most commonly violated provisions within the standard.

1. 147(c)(4)(i) — General procedures

Employers must develop, document and follow procedures to control hazardous energy when employees service or maintain machines or equipment that could harm them when started up or unexpectedly energized or when stored energy is released.

The procedures need to include:

• Steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy
• Steps for placing, removing and transferring lockout/tagout (LOTO) devices and the responsibility for them
• Requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other energy control measures.

Affected employees are those whose job requires them to operate or use a machine or equipment on which service or maintenance is being performed under LOTO or work in an area in which such service or maintenance is being performed.

2. 147(c)(6)(i) — Periodic inspection

OSHA requires regular inspections of LOTO procedures, with a minimum of one inspection per year. According to OSHA, the inspector must be an authorized employee other than one who uses the procedure being inspected.

Where lockout is used for energy control, the inspections must include a review between the inspector and each authorized employee to clarify that worker's responsibilities.

3. 147(c)(1) — Energy control program

Neglecting to perform periodic LOTO inspections is one thing; not having an energy control program in the first place is another. Yet according to OSHA’s log of violations, many companies don’t have one.

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4. 147(c)(7)(i) — Training

Even the best energy control program won't be effective if workers aren’t trained on it. Employers must provide training to help workers understand the purpose and function of the program and teach them how to safely apply, use and remove energy controls.

This provision spells out several areas training should cover. For example:

• Authorized employees must be taught to recognize hazardous energy sources and appropriate means for energy isolation and control.
• Affected employees must be trained in the energy control procedure.
• Employees who work or might work in areas where energy control procedures may be used should be instructed about the procedure and about prohibitions on restarting or reenergizing LOTO machines or equipment.

5. 147(d) — Application of control

LOTO procedures must include certain actions performed in the appropriate sequence. For example:

• Preparing for shutdown, which includes knowing of the type and magnitude of the energy to be controlled
• Shutting down the machine or equipment using established procedures
• Isolating it from the energy source
• Applying the lockout device or affixing the tag in the proper place

According to OSHA, compliance with the LOTO standard prevents an estimated 120 fatalities and 50,000 injuries each year. It can also save your company time and money. Workers hurt on the job from hazardous energy lose an average of 24 days of work.

Better safe than sorry. Check out OSHA’s LOTO fact sheet for more information.