OSHA Cites Lockout Tagout Again!

Over the past several months, we have received various calls relating to OSHA visits and citations relating to mechanical Lockout Tagout (LOTO), OSHA Standard, 1910.147.  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 and/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.

Below are key areas that are often forgotten when implementing a mechanical lockout tagout process:

1. 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.
   
2. Annual Re-assessment: OSHA requires an annual review of your LOTO process and this review must be documented and certified by the reviewer.  If Tagout is used (i.e., applying a warning Tag to the isolating device, versus a Lock) you must also review how employees in the area are impacted, or otherwise affected by the process.
   
3. Lock, Tag, Try or Test: Remember, Lockout and Tagout are two separate processes.  We believe adding a try or test component is one that is beneficial in helping individuals remember the requirements as it relates to trying to start the equipment or machine, or testing it to ensure 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.