Approximately 3 million workers service equipment and face the greatest risk of injury if lockout/tagout is not properly implemented. Compliance with the lockout/tagout standard (29 CFR 1910.147) prevents an estimated 120 fatalities and 50,000 injuries each year. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation. In a study conducted by the United Auto Workers (UAW), 20% of the fatalities (83 of 414) that occurred among their members between 1973 and 1995 were attributed to inadequate hazardous energy control procedures specifically, lockout/tagout procedures.
Lockout / Tagout (LOTO) and Hazardous Energy Control / Control of Hazardous Energy refers to the same standard of preventing unexpected start-up or movement of equipment. The terms are used interchangeably, although “Lockout Tagout” or “LOTO” is more universally used in common language, while “Control of Hazardous Energy ” is often used as the name of a code or standard.
The #1 most cited OSHA regulation for manufacturing is Lockout-Tagout (LOTO). In addition to increasing all minimum and maximum penalties by 7% in January 2023, OSHA also issued a memorandum to its regional administrators granting additional leeway for issuing instance-by-instance citations for high-gravity serious violations, with lockout listed as an area of focus.
Proper application of lockout-tagout (hazardous energy controls) violations are on OSHA’s Top 10 “Most Often Cited Violations” and Top 10 “Most Serious Violations” lists. While many companies have general written policies, they are lacking the equipment-specific procedures which provide workers with the specific steps to properly isolate energy sources. Lockout / Tagout fines are based on each piece of equipment and can add up to tens or hundreds of thousands of dollars.
OSHA CFR 29 1910.147 provides regulations on LOTO and 25 states have their own approved lockout tagout / blockout programs. The most overlooked aspect of a lockout tagout program is failing to provide equipment-specific lockout procedures. A general corporate written policy does not meet the requirements of OSHA.
State OSHA Programs | Federal OSHA Programs | ||
---|---|---|---|
Alaska (AK) | New Mexico (NM) | Alabama (AL) | Montana (MT) |
Arizona (AZ) | New York (NY) | Arkansas (AR) | Nebraska (NE) |
California (CA) | North Carolina (NC) | Colorado (CO) | New Hampshire (NH) |
Connecticut (CT) | Oregon (OR) | Delaware (DE) | North Dakota (ND) |
Hawaii (HI) | Puerto Rico (PR) | Florida (FL) | Ohio (OH) |
Illinois (IL) | South Carolina (SC) | Georgia (GA) | Oklahoma (OK) |
Indiana (IN) | Tennessee (TN) | Idaho (ID) | Pennsylvania (PA) |
Iowa (IA) | Utah (UT) | Kansas (KS) | Rhode Island (RI) |
Kentucky (KY) | Vermont (VT) | Louisiana (LA) | South Dakota (SD) |
Maryland (MD) | Virgin Islands (VI) | Maine (ME) | Texas (TX) |
Michigan (MI) | Virginia (VA) | Massachusets (MA) | West Virginia (WV) |
Minnesota (MN) | Washington (WA) | Mississippi (MS) | Wisconsin (WI) |
Nevada (NV) | Wyoming (WY) | Missouri (MO) | |
New Jersey (NJ) |
There are 5 main components to a lockout tagout program:
The most common problem found in lockout / tagout compliance is the lack of written equipment-specific procedures. Having an overall plan (company lockout / tagout policy) is only one part of lockout / tagout compliance and does not bring a facility or plant into full compliance. Contact your Martin Technical Lockout Expert to get a lockout program evaluation or a quote on the services you need.
American National Standard ANSI / ASSE Z244.1 Control of Hazardous Energy – Lockout/Tagout and Alternative Methods Standard is a publication by the American Society of Safety Engineers. The standard provides more detailed information, especially on alternative lockout methods than OSHA, and can be used as an industry standard to reference.
As stated above, some states have their own OSH programs that can have some differences from the federal OSHA programs. The State of California, General Industry Safety Order, calls its program lockout / blockout. Blockout refers to the “blocking” of equipment that can rotate or move due to gravity. Blocking out moving parts is part of any lockout program.
American National Standard ANSI / ASSE Z244.1 Control of Hazardous Energy – Lockout/Tagout and Alternative Methods Standard is a publication by the American Society of Safety Engineers that is similar to OSHA 1910.147 compliance requirements.
Unlike OSHA, this is not a federal code but rather a standard. The ANSI standard provides more detailed information, especially on alternative lockout methods than OSHA, and can be used as an industry standard to reference, and is sometimes used outside of the United States when there is no country codes on the control of hazardous energy.