FSP0016 – Lockout/Tagout (LOTO) – Facility Science Podcast #16

Notes for FSP0016 – Lockout/Tagout (LOTO)

Note: I’m going to cover this topic in the context of the standard set by OSHA in the United States (Occupational Safety and Health Administration) because that is the applicable standard where I am. While other countries may have different regulatory agencies and standards, the general LOTO concepts are universal.

Another note: I don’t consider myself to be an expert on this topic. I’m sharing with you what I have learned through both experience and study over the years. You should consult with your trusted safety experts and insurance providers and local regulatory agencies and experienced technicians and etc

What is LOTO?

A practice intended to protect maintenance and service workers and also nearby workers and bystanders from being exposed to hazardous energy during servicing and maintenance of machines and equipment.
Exposure to hazardous energy in this case could be due to unexpected energization or startup of the equipment during service or maintenance or due to the release of energy stored in the equipment.
“Hazardous energy” can be electricity, thermal energy (steam or hot elements or hot air), energy stored in hydraulic or pneumatic devices, energy stored in compressed gas systems, mechanical energy stored in springs or gravitational potential energy, or something large and/or heavy that might move unexpectedly.
The basic idea is that before we work on anything that might expose us to hazardous energy we:
- identify the sources of hazardous energy and disconnect them and then secure them in such a way that only the worker (or workers) doing the work can reconnect the source of hazardous energy to the equipment. This is typically done using a padlock or something similarly strong with they key to the lock being controlled by the worker.
- identify any sources of stored energy in the equipment and either safely release the stored energy or secure the energy storage mechanisms in such a way that the energy won’t be released during the service work while the worker is in harm’s way..
- The disconnecting means or energy isolation devices are things like circuit breakers, disconnecting switches, valves, etc, basically anything that can be operated or removed or otherwise blocked to prevent the release of hazardous energy.
Sometimes we’re going to do dangerous things in order maintain a certain level of safety and comfort and productivity, but there’s no reason to make those things any more dangerous than they need to be. LOTO is one of the ways we try to address that idea.

Getting into the OSHA standard (CFR 1910.147):

Applicability of the standard

LOTO standard applies when:
- An employee is required to remove or bypass a guard or other safety device.
  - This can be the outside casing or body panels of a machine that might expose moving parts or electrical components.
  - Could also be something as simple as the ballast cover inside a fluorescent light fixture.
- An employee is required to place any part of their body into an area on a machine or piece of equipment where work is actually performed upon the material being processed or where an associated danger zone exists during a machine operating cycle.
LOTO standard doesn’t apply when:
- Working on cord and plug connected equipment where unplugging the equipment eliminates the risk of exposure to hazardous energy as long as the person performing the work has exclusive control of the plug. (In order for someone to plug the machine back in they would have to forcefully take the plug from the control of the maintenance worker and they wouldn’t be able to do so without it being very clear to the worker that they need to get out of the way…If the work is being done on a piece of plugged connected equipment but the plug is across the room from where the worker is actually working, LOTO does apply).
- Also, there are some other industry specific exceptions in the pipeline and electric utility industries which are things that I’m not super familiar with. My guess is that if you are involved in any of these situations you probably know about this.

Who is responsible for LOTO? (Everyone) (responsibility might be legal, ethical, moral)

Before I talk about responsibilities, I want to give two definitions from the OSHA standard.
- “Affected employee: An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout or whose job requires him/her to work in an area in which servicing or maintenance is being performed.”
- “Authorized employee: A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee’s duties include performing servicing or maintenance covered under this section.”
The employer
- Under the OSHA rules, it is the employer’s responsibility to (quoting from the standard) “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 means that for each piece of equipment, or for each maintenance procedure (whichever makes the most sense), the employer will identify the sources of hazardous energy and identify the means to disconnect or otherwise control exposure to the sources of hazardous energy. This information, along with the exact lockout procedure should be documented in a way that is available to and clearly understandable by the people who will be performing the work. Quoting from the standard again: “The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following:”
  - “A specific statement of the intended use of the procedure.”
  - “Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy.”
  - “Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices and the responsibility for them.”
  - “Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.”
- Before authorizing an employee to perform potentially dangerous work, the employer will train that employee on the hazards associated with the work they will be expected to do and the procedures necessary to protect themselves from those hazards (so the lockout/tagout procedures).
- Will provide all of the appropriate protective materials and hardware – locks, tags, chains, wedges, blocks, pins, or whatever else is needed to properly secure the sources of hazardous energy in each situation.
- Periodic inspection that procedures are being carried out properly
  - OSHA says at least annually
  - Inspection should be done by an authorized employee other than the one actually carrying out the energy control procedure. Basically we want someone who understands the LOTO procedure and the hazards associated with the service or maintenance work to look over the shoulder of the person performing the LOTO procedure and verify that they are properly following the procedure.
  - Inspections should be documented with respect to the procedures being used, the date of the inspection, employees included in the inspection and the inspector.
- Training affected employees and other employees working in the facility about their responsibilities under LOTO
The maintenance or service employee (OSHA calls this an authorized employee)
- Understand the dangers associated with the work they are expected to do and the means to protect themselves and others around them – If you’re this person, it’s your responsibility to decline to do a job if you don’t understand what can go wrong and how to prevent it.
- Before work is started – follow the equipment-specific hazardous energy control procedure
  - notify all affected employees (the equipment operators or other nearby employees that might be affected by release of hazardous energy in the area)
  - properly shut down equipment
  - isolate the equipment from sources of hazardous energy
  - Apply the appropriate lockout or tagout devices.
  - Release or otherwise secure any sources of stored or residual energy.
  - Verify that isolation has been achieved by the appropriate tests or measurements or observations.
- When work is complete and it’s time to re-energize the equipment:
  - Remove all nonessential items from the area (you don’t want to leave your wrench inside the machine) and make sure the machine or equipment is properly reassembled and in working order and the controls are in a safe configuration.
  - Ensure that all employees are in a safe place relative to the potential hazard of re-energization.
  - Remove the lockout devices and energize the equipment.
  - Notify affected employees that the equipment is no longer under LOTO.
Equipment operators or other employees working nearby (affected employees)
- Understand the purpose of LOTO and how it will be used in their area.
- Understand their specific responsibilities and hazards (don’t attempt to operate or energize the machine, leave the area if necessary, etc).
Everyone else in the facility.
- Understand the purpose of LOTO.
- Identify LOTO devices and understand not to try to energize LOTO’d equipment or remove LOTO devices.

Lockout or Tagout?

First, the difference between lockout and tagout
- A lockout device is (from the standard), “a device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in a safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.” There is some disagreement over whether blank flanges and bolted slip blinds are actually technically “lockout devices” which is, we’ll say, outside the scope of this podcast. From a practical perspective, we only need to consider whether they provide the intended degree of protection.
- A tagout device is (again from the standard), “a prominent warning device, such as a tag and a means of attachment, which can be securely fastened to an energy isolating device in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.
- The main difference is that the lockout device is more robust and physically prevents the operation of the energy isolating device while a tagout device is more of an indicator, and while tagout devices are required to be reasonably robust, they don’t provide anything near the degree of protection that a lockout device provides.
The OSHA standard (and maybe common sense) basically says that we should use lockout unless we can’t. Additionally if we use tagout instead of lockout, we have to demonstrate that the tagout procedure provides the same degree of protection that a lockout procedure would.

Group LOTO, work that spans multiple shifts, outside contractors

Sometimes there are more than 1 person working on a particular job where a LOTO procedure is required. In this case:
- the lockout arrangement should be configured so that each worker can apply their own lock.
- Each individual worker’s lock should be sufficient to control the source of hazardous energy. In other words, the energy isolating device should not be operable until the last worker removes their lock.
- There are various methods to accomplish depending on the exact circumstances.
When work spans multiple shifts
- The standard requires procedures to transfer LOTO control between outgoing and incoming employees. Typically workers from the 2 shifts would meet at the control point. The incoming worker(s) would apply their lock, then the outgoing worker would remove theirs. The details, of course, are situation specific.
Outside contractors
- The OSHA standard says that “whenever outside servicing personnel are to be engaged in activities covered by the scope and application of this standard, the on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures. The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer’s energy control program.” and this is to make sure nobody inadvertently does something that hurts someone else. I don’t think the standard specifically addresses this, but it also makes sense that the party that knows more about the dangers of a particular tasks (either the outside contractor or the on-site employer) should advise the other on any deficiencies they notice in their particular procedure.

Removing LOTO devices

LOTO devices should be removed only when the authorized employee has completed their work and verified that it is safe to re-energize the equipment.
LOTO devices should only be removed by the employee who applied the device. This is important.
In real life, we may have to make an exception to the rule. There may be circumstances where the employee who applied the LOT device isn’t available to remove it. OSHA addresses this, and I’ll read from the standard again: “When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures and training for such removal have been developed, documented, and incorporated into the employer’s energy control program. The employer shall demonstrate that the specific procedure provides equivalent safety to the removal of the device by the authorized employee who applied it. The specific procedure shall include at least the following elements:”
- “Verification by the employer that the authorized employee who applied the device is not at the facility.”
- “Making all reasonable efforts to contact the authorized employee to inform him/her that his/her lockout or tagout device has been removed.”
- “Ensuring that the authorized employee has this knowledge before he/she resumes work at that facility.”

Lockout/Tagout devices

Lockout/tagout devices should be conspicuously and unambiguously identifiable as lockout/tagout devices.
LOTO devices should not be used for any other purpose and non-LOTO devices shouldn’t be used for LOTO purposes – these are intended to be safety devices, so we want it to be clear to everyone what is going on when they see a LOTO device.
LOTO devices should be durable – they should be able to withstand the environment they will be exposed to for the maximum amount of time they are expected to be exposed without loss of effectiveness
LOTO devices should be standardized – every employee in the facility should be immediately be able to identify the LOTO device as a LOTO device.
LOTO devices should be substantial – Lockout devices shouldn’t be removable by an unauthorized person without “excessive force or unusual techniques”.
There are plenty of vendors of compliant LOTO devices for general use, but it also might be necessary to develop custom devices for particular use cases.
Lockout/tagout devices should never be removed by anyone other than the person that applied them except by documented procedures under very specific circumstances. Basically, the LOTO devices are intended to protect the person who applied them. The only person in harms way should be the person that applied the LOTO devices, so therefore the only person with the knowledge to safely remove a LOTO device is the person who applied it.