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OSHA Cites
Lockout Tagout Again
Over the past several months, we have received various calls relating to OSHA visits and citations involving mechanical Lockout Tagout (LOTO), OSHA Standard 1910.147. The establishments being visited were a mix of manufacturing and other general industry operations.
Lockout Tagout relates to de-energizing anything that has energy that, if not controlled or discharged before performing work related functions on that item, can reach out and injure you. Energy sources include electric, pneumatic, hydraulic, or the weight of the part, equipment, or process itself.
This applies not only to machinery and equipment, but to processes as well. For example, when a vehicle is elevated on a jack, the energy is the vehicle itself should it, or part of it, fall.
Three LOTO Requirements That Are Often Forgotten
Below are key areas that are often forgotten when implementing a mechanical lockout tagout process.
- Site Specific Inventory: Many workplaces have a great general policy but forget to perform a site-specific inventory of all energy sources for equipment or operational processes that must be maintained or serviced.
- Annual Reassessment: OSHA requires an annual review of your LOTO process, and this review must be documented and certified by the reviewer. If Tagout is used, meaning a warning Tag is applied to the isolating device rather than a Lock, you must also review how employees in the area are impacted, or otherwise affected, by the process.
- Lock, Tag, Try or Test: Remember, Lockout and Tagout are two separate processes. We believe adding a try or test component is beneficial in helping individuals remember the requirements, because it prompts them to try to start the equipment or machine, or test it, to confirm the process is not LIVE after a Lock or Tag is placed. It is good practice to include this in site procedures and in LOTO training.
While yearly training is not required unless your annual assessment shows there are deficiencies, we encourage you to perform short educational reminder sessions anyway to help build mindset and promote injury prevention.
Where SSCI Can Help
- General Industry Safety Consulting, including LOTO program review, site-specific energy source inventories, and annual certification support.
- Safety Performance Review, a structured look at where your compliance and injury prevention gaps actually are.
- MiltSafe® Safety Talks, short, ready-to-deliver talks your supervisors can use for LOTO reminder sessions.