Lockout/Tagout – Self-Checklist
Lockout/Tagout is one of the first topics that may come to mind when we think of safety procedures and OSHA regulations. Even though Lockout/Tagout may be well known in name, many employers may be missing one or more key parts of the program. Due to the importance of this procedure in preventing a variety of injuries, including amputation and loss of life, it is vitally important that a complete and thorough understanding is held. Further, that understanding must translate into each of the elements being effectively implemented.
Take a few moments to look at your program evaluating whether or not you are compliant. If your program is missing key elements, the results could be severe injuries, property damage, OSHA citations, and loss of life.
- A written Lockout/Tagout Program needs to be developed by a knowledgeable person based on the OSHA standard.
- Machine-specific procedures are required when multiple energy sources exist.
- Locks and tags must be standardized, provided by the employer, and must not be used for any purpose other than LOTO.
- Locks and tags must not be removed by others except under a very specific procedure that prevents exposure to the unexpected release of energy. This responsibility is normally assigned to someone of authority who will follow the safe procedure for lock removal.
- Training is required before employees are exposed to hazards for several employee groups known as;
Authorized: Those who will perform Lockout/Tagout
Affected: Those working in areas where Lockout/Tagout is in use
Other: Those who work in the facility but are unlikely to encounter Lockout/Tagout
(e.g. office workers)
- Authorized workers must be trained initially, re-trained whenever there are changes in equipment or procedures, and then also re-trained whenever there are deficiencies noted in their use of the procedures.
- Annual inspections are required to assure that all LOTO Authorized workers are following all the requirements and steps in your program.
- One often overlooked step in the LOTO procedure is notifying affected employees in the area who might otherwise attempt to operate a machine being serviced.
- Another frequently overlooked step can be addressed by changing the terminology you use around the shop. Instead of saying “Lockout/Tagout” you may want to start calling it “Lockout/Tagout/Tryout.” This refers to the practice of always trying the start button before doing any repairs. It is amazing how many times we have seen a machine that is reportedly locked out start up when the start button is pressed.
- There are some situations when frequent positioning, testing, and unjamming may make LOTO difficult to enforce. Some of those situations may be covered by an exception to the LOTO rule, but only if past experience proves that alternate methods are adequate. Relying on this exception has caused many severe injuries, amputations, and worse. Make sure you have fully considered any exceptions to the requirement of locking out equipment for service.
Lockout/Tagout can be somewhat confusing and difficult to implement. But, it doesn’t have to be. It really is an important and vital part of any effective safety and health program. If you have questions or would like to discuss the compliance of your program, don’t hesitate to give us a call. We are here to help.